<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
United States securities and exchange commission logo





                              January 23, 2024

       Kenneth D. DeGiorgio
       Chief Executive Officer
       First American Financial Corporation
       1 First American Way
       Santa Ana, CA
       92707-5913

                                                        Re: First American
Financial Corporation
                                                            Form 8-K/A
                                                            Filed January 12,
2024
                                                            File No. 001-34580

       Dear Kenneth D. DeGiorgio:

                                                        We have reviewed your
filing and have the following comment.

              Please respond to this letter within ten business days by
providing the requested
       information or advise us as soon as possible when you will respond. If
you do not believe a
       comment applies to your facts and circumstances, please tell us why in
your response.

                                                        After reviewing your
response to this letter, we may have additional comments.

       Form 8-K/A

       Item 1.05 Material Cybersecurity Incidents, page 1

   1.                                                   We note the statement
that you expect the cybersecurity incident will have a material
                                                        impact on the fourth
quarter of 2023 results of operations, but that you do not believe the
                                                        incident will have a
material impact on your overall financial condition or on your
                                                        ongoing results of
operations. Please advise us whether you filed this amended Form 8-K
                                                        pursuant to Instruction
2 to Item 1.05 and confirm, if true, that you determined the
                                                        incident was material
to you under the standard in cases addressing materiality under the
                                                        securities laws,
including TSC Industries, Inc. v. Northway, Inc. Additionally, please
                                                        clarify in future
filings any known material impact(s) that are likely to continue after the
                                                        fourth quarter. In
considering material impacts, please describe all material impacts. For
                                                        example, consider
customer relationships, potential reputational harm, and the impact due
                                                        to exfiltrated data,
whether or not from non-production systems.
 Kenneth D. DeGiorgio
FirstName  LastNameKenneth   D. DeGiorgio
First American Financial Corporation
Comapany
January 23,NameFirst
            2024     American Financial Corporation
January
Page  2 23, 2024 Page 2
FirstName LastName
        We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.

       Please contact Cheryl Brown at 202-551-3905 or James Lopez at
202-551-3536 with any
other questions.



                                                          Sincerely,

                                                          Division of
Corporation Finance
                                                          Office of Finance
</TEXT>
</DOCUMENT>
