First Horizon Corporation (FHN) Earnings Call Transcript & Summary

June 10, 2024

New York Stock Exchange US Financials Banks conference_presentation 38 min

Earnings Call Speaker Segments

Unknown Analyst

analyst
#1

All right. Up next, we have First Horizon. I'm going to get our regular disclosures out of the way first, which is -- for important disclosures, please see the Morgan Stanley Research Disclosure website at morganstanley.com/researchdisclosures. The taking of photographs and use of recording devices is not allowed. If you have any questions, please reach out to your Morgan Stanley sales representative. And with that, we're delighted to have with us today, Bryan Jordan, Chairman, President and CEO of First Horizon and Hope Dmuchowski, CFO of First Horizon. Thank you so much for joining us.

D. Jordan

executive
#2

Thanks for having us. feel like I ought to get our disclosures out of the way, too.

Unknown Analyst

analyst
#3

Go ahead.

D. Jordan

executive
#4

No.

Unknown Analyst

analyst
#5

All right. So Bryan, I wanted to start big picture and get some of your thoughts on the macro environment. What is sentiment like in your markets? What are you hearing from customers? And what's the expectation from customers for the economy near term?

D. Jordan

executive
#6

Yes. In the recent few months, it seems to have slowed down a little bit. People are still generally positive, but loan demand has slowed. And whether that's a function of the fact that rates have not been cut at this point, people are generally optimistic, however. So I think we're in a good place. The economy in the south is extraordinarily strong, it continues to see in migration of folks in most markets. And customers are generally positive, but it seems to have slowed a little bit in the last couple of months.

Unknown Analyst

analyst
#7

And is it just a function of rates in your mind if rates come down, that demand should pick up? Or is it more than that?

D. Jordan

executive
#8

I think it's -- I think rate has a lot to do with it. I think it's very clear that fewer transactions or investments pencil out with a 5.5% in area of Fed funds versus something lower. And I think at the end of last year, you got a little bit of optimism that rates were going to cut a number of times over the course of the year. Inflation has been sticky. And as a result, I think people have pulled back a little bit in the near term.

Unknown Analyst

analyst
#9

So does it feel like you need a lot more rate cuts for things to pick up or a few rate cuts down should start to get the economy moving?

D. Jordan

executive
#10

I actually think it's the latter. I think if you get a couple of cuts, I think that will encourage people's optimism that there is a path and that the Fed is on it. I think -- I personally am in the camp that if we get one cut late this year, I would be surprised. I think there's a real good chance that we don't get any cuts this year given the overall stickiness that we're seeing with inflation at this level. Two days from now, we'll know more.

Unknown Analyst

analyst
#11

Yes. I know maybe when I started dropping the questions a couple of weeks ago, the rate environment was a little bit different than it is right now. You noted maybe you don't get a Fed rate cut this year. And I think you've been in that higher for longer camp for quite some time now. What do you think the Fed needs to see to start easing here.

D. Jordan

executive
#12

I think they need to see -- I think they've been very direct about it. They need to see sustainable progress that we're approaching that 2% target. And I don't know whether you measure that in months or quarters, they seem to be talking about months at this time. But I think you've got to see that over the next 2 or 3 or 4 months, and then I think you'll see the Fed start to cut rates.

Unknown Analyst

analyst
#13

And in your mind, given that you are in that higher for longer camp, do you think the next move could be a Fed rate hike? Or what do you assess as the probability of that?

D. Jordan

executive
#14

I would say it's not off the table in my view, but I think it's rather unlikely that the next move is an increase. I think you will have a whole lot of forecasting and verbal communication before that becomes a real possibility. I know there's been a little bit, but I don't think it's a real possibility today. And it really doesn't show up in the dot plot. I think we get a new dot plot this week, which, in some ways, is useful, but it also answers just 1 or 2 of the questions, not all of them. So I'm in the camp that you wouldn't get a rate increase without a whole lot more clarity from the Fed.

Unknown Analyst

analyst
#15

Got it. And maybe before we dig into some of the balance sheet items, just to get your sense more of another macro theme is this whole interplay between quantitative tightening and the RRP balances, right? RRP has been a little bit more of a buffer to QT more recently. How do you see that playing out? And if RRP is a little bit less of a buffer here, do you see that starting to impact bank deposits and in turn bank deposit competition?

D. Jordan

executive
#16

Well, I think the tightening and shrinking of the Fed balance sheet has clearly impacted the competition for bank deposits. I think the RRP is down from $2 trillion area to $500 billion or so today. I think deposit competition in a QT world is going to continue to be intense. And I would say that if anything, you've seen sort of in combination of people moving up and some folks moving down like we have been, I think you've sort of reached an equilibrium in terms of deposit rates. I think bank reserves at the Fed are still fairly significant. And then I think that is probably less a reaction to what's going on in the economy as it is just the necessary desire to have high-quality liquid assets available. And so I think we're at a place where the tension in the deposit system is still moderately high.

Unknown Analyst

analyst
#17

So that's interesting. I want you to hold that thought on the HQLA because I do want to dig a little bit into the liquidity side as well. But before that, maybe on the deposit side question for both of you, as we think about the liability side of the balance sheet, you ran a pretty successful deposit campaign last year, and you've been able to reprice a lot of those promotions down. What should we expect on deposits from here? How competitive is the environment right now?

Hope Dmuchowski

executive
#18

Competition has stayed pretty high in this rate, especially as we think about how consumers have changed their mindset. They're very aware of rates. Now they're aware of their money is making money for them. We've seen it pretty much stable from last quarter. We said in our last earnings call, we thought we'd walk back deposit rates as much as we could. We've retained 90-plus percent of the clients that we promote price last summer. We're really focused on retaining the client and the clients just have less money sitting in their accounts today than they did a year or 2 years ago. H.8 data is about 2% down quarter-over-quarter, and we're pretty much in line with that.

D. Jordan

executive
#19

Yes. I think I think that the competition for deposit rates has sort of reached that equilibrium point. I would say a year ago, 8 months ago, you still had a lot of institutions on what was self-described as risk-weighted asset diets. And over the course of the last 6 to 8 months, you've seen loan competition actually increase. You've seen loan pricing become more competitive. And as a result, deposit pricing has become more competitive. And so I think it will remain reasonably high. I think the ability to, in our case, to move rates down significantly from here is probably lesser today than it was 4, 5, 6 months ago.

Unknown Analyst

analyst
#20

Some banks today have been talking about how they've been doing a few more targeted rate reductions and different deposit types or in different deposit regions. One of your peers earlier today mentioned that you could see deposit pricing go down a little bit from here, even if the Fed doesn't cut rates. I guess you guys have already done a lot more in bringing those promotional costs down. But how do you think about that dynamic playing through if the Fed stays higher for longer?

D. Jordan

executive
#21

I think if the Fed stays higher for longer, as Hope that people are very attuned to what is available in the deposit market. And I think as a result, you've put generally a floor broadly speaking, under deposit rates. Now that's not to say that you could move from long-term CDs to something shorter term like savings accounts or money markets. But at the end of the day, I think you broadly speaking on the cost of deposits, you've probably seen most of the movement until the Fed starts cutting rates.

Unknown Analyst

analyst
#22

And does that move from CDs to money market deposits. Is that essentially just a mix shift in the line item without being a mix shift in rate? Or does that come at a slightly lower rate as well?

D. Jordan

executive
#23

It's a combination of things. It's really where you're choosing to advertise and what you're putting out there is special. It really is where you want to be on the yield curve and for what duration. And in our case, a year ago, we were competing with 6-month promotional rates. We've shortened that 3-month promotional rates with the idea that the next move from the Fed is down and having shorter promotional periods. And I think people are thinking about CDs in a similar fashion.

Unknown Analyst

analyst
#24

And what has the receptivity been there in terms of both deposits on the consumer side as well as the commercial side. What differences are you seeing on deposit behavior there on the rate-sensitive deposits as well as on the core operational deposits.

Hope Dmuchowski

executive
#25

Our core operational deposits are pretty much flat quarter-over-quarter. We're not seeing a whole lot of migration there. As Bryan always said -- just to talk about it. The money market and CD we're definitely seeing a change. This time last year, we were offering 11-month CD rates. Now we're looking at much shorter terms and a lower rate. The difference in rate between CDs and money markets is getting much closer. So you're just not seeing the mix change that we saw a year ago. The closer we all get to that first rate cut, the duration is coming down on those rate offers.

D. Jordan

executive
#26

Yes. I would say in terms of noninterest-bearing -- sort of reached that point of inflection where it's more at that stabilized level. And you go look at what people are doing in terms of transactions in their account, ACHs, where balances need to be. That has reached a more stable level. And there's much more stability in terms of rate fluctuations even in the interest-bearing accounts. At the end of the day, you're going to have a little bit of seasonal inflows and outflows based on when tax payments are made, but I think you've seen a much progress towards overall stabilization at these levels.

Unknown Analyst

analyst
#27

You mentioned NIB has stabilized, and I think at earnings as well, you mentioned that NIBs, it stabilized in Feb and March. So are you saying that it's kind of continued through this quarter as well?

D. Jordan

executive
#28

Yes.

Unknown Analyst

analyst
#29

So as we think about the different customer types like between consumer and commercial, is that -- is there any differences there in how NIB has behaved or how deposit balances are there?

Hope Dmuchowski

executive
#30

No major differences. There's seasonality. When you look at when tax payments come in, when tax payments go out. Same thing with municipal money such as seasonality.

Unknown Analyst

analyst
#31

Got it. Okay. Great. Maybe let's move to loans. That's been fairly topical as well. When I look at the Fed H.8 data, loan growth has consistently stayed a week throughout this year. But maybe on the other hand, your footprint includes some of the faster-growing regions in the country. And of course, competition has also been growing. So can you talk about what the loan growth and competition look like in your markets?

D. Jordan

executive
#32

Yes. Loan growth, as I mentioned earlier, has slowed some. There's clearly not as much demand. Our competition, I would suggest, has picked up as -- over the last several quarters, you've seen much more competition on the rate side of things, not as much on the structure side at this point. But it is clear and evidence that there is less demand in the marketplace and that the demand that is out there is significantly more competitive than it was 2 or 3 quarters ago.

Unknown Analyst

analyst
#33

So it's interesting you say that because one of the questions that I had just generally across the space is, we're hearing several of your peers talk about how they're moving away from CRE and focusing more on C&I. So are you seeing more competition on the C&I side of things than on CRE?

D. Jordan

executive
#34

Yes. Absolutely more on the C&I side. There's -- there are not as many CRE deals that are coming up in this environment.

Unknown Analyst

analyst
#35

So maybe is this the right time to maybe lean in a little bit on some of the better structured CRE deals or not quite given where we are in the environment.

D. Jordan

executive
#36

Well, we take -- we have a real strong view that any time you have an opportunity to pick up a well-structured, long-term relationship opportunity you lean in. So we are leaning in, and we're focusing on those areas where we think, one, we can protect the integrity of the balance sheet, but we can greatly improve our customer relationships over the long term by leaning in. So yes, we'll even do it in CRE. Again, there's just not that many opportunities.

Unknown Analyst

analyst
#37

So then how do you think about loan growth as you get into the back half of this year? Do you see it staying pretty tepid until we get something in 2025, as we get past the elections?

D. Jordan

executive
#38

It feels to me like it's going to be reasonably tepid, I think we'll be in the range we've laid out, I think will be towards the lower end of those ranges just given what we're seeing in terms of activity today. But all in all, I think it will take some sort of catalyst, whether it's the elections, whether it is the Fed cutting rates and causing people to be more optimistic about the direction of the economy. I don't know what the catalyst will be, but I think we need some sort of catalyst.

Unknown Analyst

analyst
#39

So as I think back to the start of this year, I think several banks were talking about how loan growth should pick up in the back half. So it feels like the banks are positioning their balance sheets to ahead of that loan growth. So if that loan demand doesn't come through, is that kind of having an impact on spreads at this stage? Or is that not quite happening just yet?

D. Jordan

executive
#40

It has an impact on growth in NII. The yields on the asset side of our balance sheet will continue to improve as securities at lower rates continue to mature and roll into higher-yielding assets, fixed rate loans do the same thing. But it does have an impact on the net interest income growth in terms of the aggregate level.

Unknown Analyst

analyst
#41

Got it. Okay. And I think one of the more unique aspects of First Horizon's business model is your specialty business lines, mortgage warehouse, asset-based lending. Can you talk about how are those businesses performing? And do you kind of approach them differently in this environment?

D. Jordan

executive
#42

Those businesses have continued to perform very well. They have done an excellent job of managing credit, credit quality and have overall strong relationships. Demand is somewhat softer there as well, but we're still seeing opportunities to pick up long-term relationships in our specialty businesses as well. And I think in terms of our ability to generate higher-yielding long-term relationships, they're still very, very attractive in terms of driving our ability to perform, producing higher returns over and throughout cycles.

Unknown Analyst

analyst
#43

And maybe if you can dig in a little bit on mortgage warehouse versus asset-based lending, franchise finance or any specific areas doing better than the other?

D. Jordan

executive
#44

Well, in mortgage warehouse lending, for example, it's largely a purchase money market. There's very little to no refinance activity. It tends to be seasonal second and third quarters. People do more moving, buying new homes, et cetera. So it's picked up a little bit. Asset-based lending has continued to be fairly steady. Our restaurant business is affected by what's going on in terms of traffic in the restaurant space, but overall, those businesses continue to do very well in the first couple of quarters of this year.

Unknown Analyst

analyst
#45

And how do you think about those businesses as bringing a more holistic relationship to the bank? Is there -- do some of these businesses bring in enough on the deposit side and you kind of leaning in a little bit more to bring in that holistic relationship?

D. Jordan

executive
#46

Well, clearly, we have made a tremendous amount of progress in growing deposits in our specialty businesses. They tend to be very high loan-to-deposit businesses and said another way, they generate significantly more assets than liabilities, but they generate very high-yielding assets. And so if you were to create a waterfall from high to low of high returning, high return on equity high-yielding assets, your specialty businesses would be on the left side or the high side of that waterfall chart. So they're very, very attractive to us in terms of driving very strong returns on capital.

Unknown Analyst

analyst
#47

So there's no change in how you'd approach those businesses as you get to $100 billion in assets?

D. Jordan

executive
#48

Well, as we get to $100 billion in assets, we have a little bit of time. And clearly, it would benefit us all to have more clarity about what Basel III endgame looks like, what that means? Will there be tiered supervision across the industry. And it gives us some flexibility, but we don't have enough information to know what the structure of that balance sheet needs to look like, we have the levers that we can pull, and we're confident, comfortable over the next, call it, 2 to 3 years as we approach $100 billion organically. We have the ability to pull the appropriate levels on the balance sheet.

Unknown Analyst

analyst
#49

Yes. I guess my question was more on the specialty business lines despite the fact that they are high loan-to-deposit ratios because the returns are pretty high on those businesses, there wouldn't be any change in how you manage those businesses?

D. Jordan

executive
#50

Well, yes, I was trying to answer it and say we don't know enough. It's one of the levers that we have to pull.

Unknown Analyst

analyst
#51

Fair enough. All right. So then maybe putting that all together on the loan side and the deposit side. At earnings, you spoke about NII growth being at the low end of the 1% to 4% guidance range this year. Is that still roughly how you're thinking about it?

Hope Dmuchowski

executive
#52

Yes, we're still thinking about 1% to 4% as loan growth, as you mentioned earlier, we had anticipated that loan growth will be higher in the second half of the year, particularly in the mortgage and mortgage warehouse business and mortgage warehouse being one of our highest-yielding assets that would have put us on the higher end of the 4%. So we'll probably come in lower on that guidance, but still well within that guidance at this point.

Unknown Analyst

analyst
#53

And maybe the forward curve is also changed. I know it really depends on the week when you look at the forward curve, but it seems like there's only one more rate -- or one rate cut coming in, in December. Does that change how you think about that NII side?

Hope Dmuchowski

executive
#54

No. Whether we have 1 rate cut, no rate cuts, 3 rate cuts. We've modeled it. We still believe we'll be in the 1% to 4%. The biggest changes for us this year are the loan growth just coming in a little bit lower on the guidance side than we've had previously and without a rate cut, just from the deposit cost competition. We had originally thought that we'd walk it back probably every quarter as we announced in Q1, the competition with the rates, not expecting that first drop till later this year has stayed higher than we had anticipated earlier in the year, but we feel strongly that we can come in within the 1% and 4% regardless of which interest rate environment we have for the rest of this year.

D. Jordan

executive
#55

We still remain asset sensitive. We've migrated closer to neutral as deposit rates have come up, but we're still asset-sensitive, and our balance sheet benefits from higher for longer.

Unknown Analyst

analyst
#56

So I don't ask you a 2025 question, but maybe I'm going to ask it indirectly, but how do you think the balance sheet is positioned. If we do go back to a falling rate environment and you get maybe 2, 3, 4, rate cuts in 2025. How do you position the balance sheet ahead of that?

D. Jordan

executive
#57

Well, we believe that the balance sheet needs to be positioned to manage it from asset sensitivity, how much asset sensitivity is really a function of where your liability costs are in the near term. But when you think about our business, it's -- you're only looking at half the story if you think about the net interest margin in isolation. While the net interest margin would be hurt slightly by falling rates, the offset is in our specialty businesses, particularly our mortgage warehouse lending business, our fixed income business and our mortgage banking business. And through various cycles, we've had significant offset in those businesses. So we're much closer to neutral than looking at one side or the other would indicate.

Unknown Analyst

analyst
#58

Got it. Before we move on to some of the other line items in the income statement, anything else to point out on the broader guide for fees or expenses for the full year?

Hope Dmuchowski

executive
#59

No, we still stand behind our guidance that we gave at the end of Q1. In our Q1 earnings call, we actually increased guidance on our fee income side, leaving both expenses and NIM changed. And we feel strongly that the back half of the year is going to be a strong finish for First Horizon.

Unknown Analyst

analyst
#60

All right. Perfect. So maybe on fees. Last year was a tough year for the fee income business on the fixed income side. And now you have higher for longer rates and presumably an inverted yield curve also impacts the business and impacts volumes a little bit. So can you talk about the outlook for that business, both this quarter as well as for the full year?

Hope Dmuchowski

executive
#61

Yes. As we expected, 2Q has softened up from 1Q. The market has just been unpredictable. So as the 10-year treasury keeps moving kind of intraday, intra hour, it's been a little softer than we saw in Q1, but we still expect to see $500,000 ADR around that benchmark this quarter. We're continuing to see the momentum. And it's really not a month by month or week by week, it's day by day as the market is trending, we'll have a good day, and then we'll have a bad day, but just averaging out throughout the first 2 months of the quarter. But -- as Bryan said, we have an asset-sensitive balance sheet with the countercyclical businesses. I think we really proved that in Q1, and we're seeing it again in Q2.

Unknown Analyst

analyst
#62

And what's the perfect environment for that business? Is it less volatility on the rate side? Is it more of an upward sloping yield curve?

D. Jordan

executive
#63

Upward sloping yield curve and rates falling.

Unknown Analyst

analyst
#64

All right. Fair enough. Okay. Moving on to the expense side. During earnings, you reiterated your full year expense guide of 4% to 6% growth this year. I know that number included a series of strategic investments that you're making on the business. Can you give us an update on what you're doing there and how those investments are coming along?

Hope Dmuchowski

executive
#65

Well, absolutely. I'll also mention that we reiterate our expense guidance even though we have increased our FHN Financial fee income for the year. So we're offsetting the commissions that come with that fee income, with the number of initiatives we've announced this year that have brought savings back into the run rate, which is what we said we would do at beginning of this year. We're going to continue to look at ways to not just invest, but how do those investments increase the operational efficiency of our business. We announced a 3-year $100 million road map with technology. We have quite a few projects that have already completed and 2 big ones that are set to complete the end of this year. And as we get through the next group of technology investments, we're looking at how do we create operational efficiencies, how do we improve the experience for the clients. And so all of our investments are meant to either improve the client experience or find a way to create a more efficient bank.

D. Jordan

executive
#66

I'm really pleased with the progress that our technology teams have made over the course of the last 12 months. And I expect by the end of this year, most of the heavy technology lifting will get completed this year. So the team has worked extraordinarily hard, and they've covered a lot of ground. And I expect by the end of this year or early in the next year, we will have the vast majority of that work done. It will hit the expense base on a rolling fashion, but the progress has been very good to date.

Unknown Analyst

analyst
#67

So as these projects get done towards the end of this year, or there should be more that you can bring out of the expense line next year and refund for some other projects in the expense side.

D. Jordan

executive
#68

Yes.

Hope Dmuchowski

executive
#69

Absolutely.

Unknown Analyst

analyst
#70

All right. Perfect. I'll move on to credit because that's been pretty topical for the industry so far. How are your clients holding up? What are you hearing from them? And how do you expect that credit performance in the near term?

D. Jordan

executive
#71

I think credit performance will continue to be very good. As you would expect, the economy with intention by the FOMC has been to slow. So you see more downgrades than you would see in a more benign interest rate environment. But borrowers are holding up very well. One of the benefits of our business is that our relationships are very deep and go back a long way, and borrowers have been very active in shoring up projects and put in additional cash into transactions. And we're encouraged by what we see in terms of credit performance, and I would expect the second quarter of this year to look a lot like the first quarter. And I don't see anything about the back half of the year that gives me any concern today.

Unknown Analyst

analyst
#72

And is that a C&I loan comment, a CRE loan comment or both?

D. Jordan

executive
#73

Yes, both.

Unknown Analyst

analyst
#74

Okay. So in terms of if you could dig in a little bit more on the commercial real estate side, anything you can share about your portfolio and what you're seeing in that industry?

D. Jordan

executive
#75

Well, we're in extraordinarily good markets, and our portfolio is one geographically diverse. It's diversified collateral type. And I mentioned it a minute ago, we have very deep and broad relationships. And from an underwriting perspective, we had very low initial loan-to-value, easy for me to say, loan-to-value on the commercial real estate side. So those portfolios continue to perform very well. As you would expect in an interest rate cycle, you are going to see things be more stressed than anyone would have anticipated on day 1, but they continue to perform very, very well. And as a result, we are very confident in our outlook for credit over the remainder of this year.

Unknown Analyst

analyst
#76

And anything to call out in terms of change in the margin over the last 2 to 3 months, whether it's not just for your portfolio, which is what you're broadly seeing across the market?

D. Jordan

executive
#77

Nothing unusual. It's -- as I said, there are not as many commercial real estate deals. You're still seeing a lot of competition for C&I. Pricing competition has picked up in the C&I space. Collateral -- structure and underwriting has not become more competitive. And I expect that at some point. We just haven't gotten there yet.

Unknown Analyst

analyst
#78

And any pressure outside of office in your markets? Anything to call out on multifamily?

D. Jordan

executive
#79

No.

Unknown Analyst

analyst
#80

Got it. Okay. Maybe moving on to capital and regulation. As we finish up here, I wanted to discuss your perspective on just the new capital rules that are being announced. But before that, just on the buyback side, you announced $650 million share buyback authorization earlier this year. I think you have retired about $150 million or so of stock in the first quarter. What's your plan for the remainder of that repurchase authority?

D. Jordan

executive
#81

Yes. As we sit here today, we've bought back something like $212 million quarter to date, including a 6.5 million share block that traded last week. And we think with the capital generation that we have in the organization, the absence of significant asset growth, we have the ability to continue to buy back stock. We've said very publicly that our expectation is we'll remain -- as we look at the rest of this year with a CET1 ratio of around 11%. And we think we have the ability to return a fair amount of excess capital at the same time, maintain a strong healthy capital base, which enables us to deal with any inflection that might come in the economy.

Unknown Analyst

analyst
#82

And 11% is certainly stronger than most of your peers as well. So I get that maybe you're getting -- you would go down to that 11% level in the near term, but as you think about the longer-term level of capital, what would make you more comfortable going below that 11% threshold?

D. Jordan

executive
#83

You said you're going to come back to regulations. So Basel endgame. But I would tell you that in a steady environment with where we are today, we believe that we can operate the company for somewhere between 10% and 10.5%. And you might go a little bit below that even if mortgage warehouse activity is very strong, for example, we think at least on a regulatory capital base given the risk in that asset, in particular, generate or attracts more capital than is necessary, but call it 10% to 10.5% area through the long term.

Unknown Analyst

analyst
#84

So in -- so between now and the long term, okay, there's mortgage warehouse in there as well, but is Basel III endgame, the bigger piece of the Basel here.

D. Jordan

executive
#85

Well, Basel III endgame will clearly have an impact on how we think about it. I don't know enough about the moving parts. Is there going to be interoperable between TLAC and common today, it appears that you got to have one and the other. And so some of those moving parts playing out, but I think it probably necessitates more capital than less over the long term.

Unknown Analyst

analyst
#86

So maybe on that question, just on the long-term debt rules? Do you have more you need to do there? How are you thinking about managing the debt?

D. Jordan

executive
#87

Well, in our case, we -- I've been fairly public, Hope has been fairly public about -- if you look at a Basel III endgame, we would have a tremendous amount of total loss absorbing capital or TLAC that we would have to issue something on the order of $4 billion of debt. Cost of that in terms of negative carry is something like $75 million to $80 million on an annual basis. I'm hopeful that, that proposal gets rightsized, but it has -- it is the biggest portion of the $100 billion cost hurdle that we would deal with. It's something like $25 million to $50 million in terms of just compliance, stress testing, living wheels, all of the other elements, and then you put TLAC, that's another $75 million to $80 million, somewhere between $100 million and $150 million. TLAC is probably the one that seems most unnecessary at this point from our perspective.

Unknown Analyst

analyst
#88

And are those numbers, the $25 million ex TLAC, is that everything from like an NII impact to an expense impact to a [indiscernible] impact? Like is that all factored in there? Is that...

D. Jordan

executive
#89

Yes. That's all in...

Unknown Analyst

analyst
#90

That's an all in number.

D. Jordan

executive
#91

Yes. It's mostly in negative carry is issuing debt and parking it in some nature of securities or the Federal Reserve.

Unknown Analyst

analyst
#92

And I guess that would add to your liquidity as well. So I guess the third part of the rules coming in as LCR. And as you -- I know you wouldn't have LCR requirements until you approach Cat 4 levels, but some of your peers are also preparing for that eventuality. What are you hearing from regulators or at least how are you positioning your balance sheet and the amount of liquidity you're holding ahead of any new requirements?

D. Jordan

executive
#93

We're not making any significant shifts in the way we're thinking about it today. There's still too much up in the air and the regulators have said they continue to process through the comments and Vice Chair Barr and others have testified about how they're working through the process. So it seems premature at this point given that we're at $82 billion a day to start making a lot of significant changes.

Unknown Analyst

analyst
#94

Got it. Okay. Great. And before I move to the room for any questions, maybe last one on M&A. We've seen a handful of deals announced recently in the market on bank M&A. I know with everything you went through last year, you weren't eager to participate in that M&A market. But do any of these recent developments change your view at all?

D. Jordan

executive
#95

No. My view is very much the same as it was 6 months ago. We have a lot of opportunity in our existing franchise and footprint. We are really focused on delivering shareholder value. And given the uncertainty in the regulatory approval process, coupled with the fact that the purchase accounting marks are very difficult. And finally, that I'm not sure what problem you solve if you're $20 billion or $50 billion or whatever billion bigger. So we're going to focus on the blocking and tackling to manage our business and doing it on a high-quality fashion, growing on an organic basis and deploying capital in some of the best markets in the U.S.

Unknown Analyst

analyst
#96

Got it. Are there any questions in the room? Well, then maybe to wrap up, a question for both of you, is there any thought of the First Horizon story that you think people are missing?

D. Jordan

executive
#97

Go ahead.

Hope Dmuchowski

executive
#98

I feel -- as Bryan have been out here telling the story over and over again, but I think the biggest part is missing is a question you keep asking is M&A, M&A, M&A. It's not our focus. We know as many of our peers focus and what happened with TD, people think that we were for sale, we were not. We have a franchise that we love running in the best markets in the U.S. And as we've shown, we can give guidance. In June last year, we held an Investor Day and 30 days and hit the guidance. We gave you guidance in January of this year. We're going to hit it again this year. Actually increase our guidance in the first quarter. And so we are proud of the company we have. We are running it well, and we're excited about our future. We are celebrating our 160th anniversary as a bank this year, and we're excited to add 5, 10, 15 years on top of that in the coming years.

D. Jordan

executive
#99

Yes. That's well said. We hit the ground running last May and our franchise and our bankers and our customer relationships or some of the best in the industry, and we're very, very confident that we can create a lot of value and in that effort, we're going to keep stacking up one good quarter on top of the next and just deliver the results.

Unknown Analyst

analyst
#100

That's well said. And on that note, we'll leave it there. Thanks so much for joining us.

Hope Dmuchowski

executive
#101

Thank you.

D. Jordan

executive
#102

Thank you for having us. Thanks, everybody.

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