[CoreLogic Letterhead]
June 2, 2010
VIA EDGAR AND HAND DELIVERY
Jeffrey P. Riedler
Assistant Director
Division of Corporation Finance
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549-7010
Re: | The First American Corporation |
Form 10-K for the fiscal year ended December 31, 2009
Filed March 1, 2010
Schedule 14A filed April 13, 2010
File No. 001-13585
Dear Mr. Riedler:
This letter responds to your letter, dated May 20, 2010, regarding the Form 10-K for the fiscal year ended December 31, 2009, filed March 1, 2010, and Schedule 14A, filed April 13, 2010, each filed by The First American Corporation, predecessor to CoreLogic, Inc. (the “Company”). Each of your comments is set forth below, followed by our corresponding response.
Schedule 14A filed April 13, 2010
Transaction with Management and Others, page 33
Comment 1
We note your discussion of the loan agreement, promissory note and Collateral Trust Agreement entered into in connection with your loan of $9,500,000 to NHSA JPS LLC. Please file each of these agreements as an exhibit. If the agreements have already been filed, please indicate where they may be found and confirm that you will incorporate the agreements by reference into your future Form 10-K filings so long as the loan remains outstanding.
Response 1
As a result of the Company’s spin-off of its financial services businesses, the loan to NHSA JPS LLC has been transferred to First American Financial Corporation. The Company is no longer a party to the loan. We note that First American Financial Corporation has filed the loan agreement, promissory note and Collateral Trust Agreement as exhibits to its Form 10-Q for the quarter ended March 31, 2010.
If you should have any questions or further comments, please direct them to me at (714) 250-7662. Facsimile transmissions may be sent to (714) 250-6917.
Very truly yours,
/s/ Stergios Theologides, Esq
Stergios Theologides, Esq.
cc: | Sean P. Griffiths |
Gibson, Dunn & Crutcher LLP
200 Park Ave., 47th Floor
New York, New York 10166
Brian Lane
Gibson, Dunn & Crutcher LLP
1050 Connecticut Ave., N.W.
Washington, D.C. 20036