FHN · CIK 36966
What First Horizon Corporation told the SEC could break it.
First Horizon's disclosures lead with concentration of two kinds. Most of its business is with clients in the southern US, with banking centers clustered in Tennessee, North Carolina, Florida and Louisiana, so regional conditions weigh heavily; and beyond geography, 25% of its commercial-and-industrial portfolio is tied to the financial-services industry ($4.7 billion in loans to mortgage companies, $4.1 billion to finance and insurance companies). As a bank holding company it must meet capital requirements — a shortfall could bring FDIC actions, business restrictions or even conservatorship — and dividends from its bank to the parent are limited ($88 million available without approval). It also flags 2025 US tariffs as a macro channel that could feed into loan demand, credit losses and margins.
3 self-disclosed vulnerabilities, pulled from its own filings, each in the company’s words, with the source. This is the risk register almost nobody reads.
In its own words
What could break it.
Regulatory & policy
- bank capital requirements and subsidiary dividend restrictions (FDIC, conservatorship)medium
First Horizon must meet bank capital guidelines; failure could trigger FDIC deposit-insurance termination, business restrictions or conservatorship/receivership, and its Bank's dividends to the parent are limited ($88M available without regulatory approval at Jan 1, 2026) subject to capital-conservation-buffer rules.
“Failure to meet capital guidelines could result in actions by regulators that could have a material adverse impact on our operations or financial condition, including the termination of deposit insurance by the FDIC, the inability to receive regulatory approval for expansion or new activities, restrictions on our business, and in certain circumstances the appointment of a conservator or receiver.”
SEC filing →As of 2026 - 2025 US tariffs and trade-policy uncertainty (macro/credit channel)low
New 2025 US tariffs and potential foreign retaliation create uncertainty for economic growth, inflation and employment — macro variables that flow through to First Horizon's loan demand, credit losses and net interest margin.
“In 2025, the U.S. government announced new tariffs on a variety of goods and services. As of early February 2026, the timing, scope and duration of tariffs, as well as the timing, scope and duration of any retaliatory measures by foreign governments, remain uncertain, as does the impact of tariffs on economic growth, inflation rates, and employment rates.”
Geographic concentration
- lending concentrated in southern US; 25% of C&I tied to financial-services industrymedium
Most of First Horizon's business is with clients in the southern US (banking centers concentrated in Tennessee, North Carolina, Florida, Louisiana), and with $4.7B of loans to mortgage companies and $4.1B to finance/insurance companies, 25% of its C&I portfolio is sensitive to the financial-services industry — concentrating both regional and sector credit risk.
“Most of FHN's business activity is with clients located in the southern United States. FHN's lending activity is concentrated in its market areas within those states. As of December 31, 2025, FHN had loans to mortgage companies of $ 4.7 billion and loans to finance and insurance companies of $ 4.1 billion. As a result, 25 % of the C&I portfolio is sensitive to impacts on the financial services industry.”
SEC filing →As of 2026
The hidden graph
Who it depends on, and who depends on it.
Relationships surfaced from filings, including ones disclosed by the other side, which is how the non-obvious ones come to light.
Its customers
“First Mid Bank has $130 million available in overnight federal fund lines, including $30 million from First Horizon Bank, N.A., $25 million from Zions Bank, $20 million from U.S. Bank, N.A., $20 million from BMO Bank, N.A., $20 million from Bankers' Bank., and $15 million from The Northern Trust Company.”
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