Code of Ethics Waivers

January 2017

Dr. James L. Doti serves as a director of First American Financial Corporation (the “Company”) and as a director of the board of Whittier Trust Company, a company offering wealth management and investment solutions for affluent individuals, families and foundations across the country potentially in competition with the Company’s wealth management business. After consideration of Dr. Doti’s contribution to the Board of Directors of the Company and the potential conflicts of interest presented by Dr. Doti’s relationships with the Company and Whittier Trust, the Company has waived the application of Paragraphs A (Conflicts of Interest), B (Corporate Opportunity) and D (Fair Dealing) of the Company’s Code of Ethics and Conduct with respect to Dr. Doti’s relationship with Whittier Trust.

May 2016

Parker S. Kennedy serves as chairman of First American Financial Corporation (the “Company”) and as a director of the board of the Automobile Club of Southern California (the “Auto Club”), a provider of homeowners, umbrella and auto insurance to its members in competition with the Company’s property and casualty insurance business. After consideration of Mr. Kennedy’s contribution to the Board of Directors of the Company and the potential conflicts of interest presented by Mr. Kennedy’s relationships with the Company and the Auto Club, the Company has waived the application of Paragraphs A (Conflicts of Interest), B (Corporate Opportunity) and D (Fair Dealing) of the Company’s Code of Ethics and Conduct with respect to Mr. Kennedy’s relationship with the Auto Club.

January 2012

Thomas V. McKernan serves as a director of First American Financial Corporation (the “Company”) and as chairman of the board of AAA – Auto Club Enterprises and the Automobile Club of Southern California (the “Auto Club”).The Auto Club and its affiliates, provide homeowners, umbrella and auto insurance to its members in competition with the Company’s property and casualty insurance business. After consideration of Mr. McKernan’s contribution to the Board of Directors of the Company and the potential conflicts of interest presented by Mr. McKernan’s relationships with the Company and the Auto Club, the Company has waived the application of Paragraphs A (Conflicts of Interest), B (Corporate Opportunity) and D (Fair Dealing) of the Company’s Code of Ethics and Conduct with respect to Mr. McKernan’s relationship with the Auto Club.