Correspondence 0000950170-24-134629 from First American Financial Corp (FAF)
First American Financial Corp
Date: Dec. 9, 2024 · CIK: 0001472787 · Accession: 0000950170-24-134629
AI Filing Summary & Sentiment
File numbers found in text: 001-34580
Referenced dates: November 7, 2024
Letter
Division of Corporation Finance Attention: Robert Arzonetti Form 10-K for the Fiscal Year Ended December 31, 2023 Filed February 21, 2024 Response Dated September 20, 2024 File No. 001-34580
Dear Mr. Arzonetti :
We are in receipt of your comment letter dated November 7, 2024. Please see our response below.
Form 10-K for the Fiscal Year Ended December 31, 2023
Item 1C. Cybersecurity, page 23
1. We note your Chief Information Security Officer (CISO) is responsible for
developing and implementing your information security program. We also note the
Information Security Oversight Committee (ISO) “oversees [your] cybersecurity
program from a management perspective.” We also note that you describe the relevant
expertise of your CISO but not of the other members of the ISO. Please revise future
filings to discuss the relevant expertise of such members of senior management as
required by Item 106(c)(2)(i) of Regulation S-K.
Response:
We acknowledge the comment and plan to add the additional information in future filings.
If you have any questions concerning the foregoing, please do not hesitate to contact me at (714) 250-3000.
Sincerely,
/s/ Lisa W. Cornehl
Show Raw Text
CORRESP 1 filename1.htm CORRESP LISA W. CORNEHL SENIOR VICE PRESIDENT, CHIEF LEGAL OFFICER December 9, 2024 Division of Corporation Finance U.S. Securities and Exchange Commission 100 F Street, NE Washington D.C. 20549 Attention: Robert Arzonetti Re: First American Financial Corporation Form 10-K for the Fiscal Year Ended December 31, 2023 Filed February 21, 2024 Response Dated September 20, 2024 File No. 001-34580 Dear Mr. Arzonetti : We are in receipt of your comment letter dated November 7, 2024. Please see our response below. Form 10-K for the Fiscal Year Ended December 31, 2023 Item 1C. Cybersecurity, page 23 1. We note your Chief Information Security Officer (CISO) is responsible for developing and implementing your information security program. We also note the Information Security Oversight Committee (ISO) “oversees [your] cybersecurity program from a management perspective.” We also note that you describe the relevant expertise of your CISO but not of the other members of the ISO. Please revise future filings to discuss the relevant expertise of such members of senior management as required by Item 106(c)(2)(i) of Regulation S-K. Response: We acknowledge the comment and plan to add the additional information in future filings. If you have any questions concerning the foregoing, please do not hesitate to contact me at (714) 250-3000. Sincerely, /s/ Lisa W. Cornehl Lisa W. Cornehl 1 First American Way, Santa Ana, CA 92707 TEL 714.250.3000 LCornehl@firstam.com ▼ www.firstam.com