LISA CORNEHL
SENIOR VICE PRESIDENT, CHIEF LEGAL OFFICER
VIA EDGAR
January 25, 2024
Division of Corporation Finance
U.S. Securities and Exchange Commission
100 F Street, NE
Washington D.C. 20549
Re: First American Financial Corporation
Form 8-K/A
Filed January 12, 2024
To the Division of Corporation Finance:
We acknowledge to the Staff that our amended Form 8-K was filed pursuant to Instruction 2 and that we applied the traditional metrics in measuring materiality. This includes both quantitative and qualitative factors cited by the Commission as well as case law, including Supreme Court guidance. We also acknowledge that, in future filings, we will disclose any known material aspects of this incident.
If you have any questions concerning the foregoing, please do not hesitate to contact me.
Sincerely,
/s/ Lisa Cornehl
Lisa Cornehl
1 First American Way, Santa Ana, CA 92707
TEL 714.250.8581
LCornehl@firstam.com ▼ www.firstam.com