SecProbe.io

November 10, 2014

Via E -mail
Mr. Mark E. Seaton
Chief Financial  Officer
First American Financial Corporation
1 First American Way
Santa Ana, CA 92707

Re:  First American Financial Corporation
 Form 10 -K for the Fiscal Year Ended December  31, 2013
Filed February 25 , 2014
 File No. 001-34580

Dear Mr. Seaton :

We have limited our review to only your financial statements and related disclosures and
do not intend to expand our review to other portions of your document.  In our comment, we ask
you to provide us with information so we may better understand your disclosure.

Please respond to this letter within 10 business days by providing the requested
information o r by advising us when you will provide the requested response.  If you do not
believe the comment applies to your facts and circumstances, please tell us why in your
response.  Please furnish us a letter on EDGAR under the form type label CORRESP that keys
your response to our comment.

After reviewing the information you provide, we may have additional comments and/or
request that you amend your filing.

Notes to Consolidated Financial Statements
Significant Accounting Policies
Escrow deposits and trust assets , page 63

1. Please tell us the dollar amount of escrow deposits held at the Company’s federal savings
bank subsidiary  classified as cash and cash equivalents versus as debt and equity
securities  at December 31, 2012 and 2013 and September 30, 20 14.  Tell us th e nature of
any restrictions as to the use of these escrow deposits and why classification as cash and
cash equivalents is appropriate.  Refer to ASC 230 -10.  Also tell us your consideration of
the disclosures required by Rule 5 -02.1 of Regul ation S -X.

Mr. Mark E. Seaton
First American Financial Corporation
 November 10, 2014
 Page 2

  We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing include s all information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.  Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

 In responding to our comment , please provide  a written statement from the company
acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosure in the filing;
 staff comment  or changes to disclosu re in response to staff comment  do not fo reclose the
Commission from taking any action with respect to the filing; and
 the compa ny may not assert the staff comment  as a defense in any proceeding initiated by
the Commission or any person under the federal securities laws of the United States.

You may contact Senior Staff Accountants Sasha Parikh  at (202) 551 -3627 or Kei ra
Nakada at (202) 551 -3659 if  you have any questions regarding the comment.   In this regard, do
not hesitate to contact me at (202) 551 -3679 .

Sincerely,

        /s/ Jim B. Rosenberg

Jim B. Rosenberg
Senior Assistant Chief Accountant