SecProbe.io

June 24, 2011
 Via Fax

 Brian Lawson Senior Managing Partner a nd Chief Financial Officer
Brookfield Asset Management Inc Suite 300  Brookfield Place 181 Bay Street P.O. Box 762 Toronto, Ontario Canada M5J2T3
Re: Brookfield Asset Management Inc
 Form 40-F
Filed March 31, 2011 Form 6-K Filed March 24, 2011 File No. 033-97038

Dear Mr. Lawson:
 We have reviewed your filing and have the following comments.  In some of our
comments, we may ask you to provide us with  information so we may better understand your
disclosure.

Please respond to this letter within ten business days by amending your filing, by
providing the requested information, or by advi sing us when you will provide the requested
response.  If you do not believe our comments apply to your fact s and circumstances or do not
believe an amendment is appropriate, pl ease tell us why in your response.
 After reviewing any amendment to your filing and the information you provide in
response to these comments, we ma y have additional comments.

Brian Lawson Brookfield Asset Management June 24, 2011 Page 2

 Form 6-K filed March 24, 2011

2010 Annual Report
 Five-Year Financial Review, page 13

1. We note your use of the measure “cash flow from operations” or “net operating cash
flow” throughout your document.  Please re vise your disclosu res throughout your
document to provide one consistent caption fo r this measure and to clearly differentiate
this measure from cash flow from operations per your consolidated statements of cash
flows.  Additionally, please explain to us a nd enhance your disclosure to clarify whether
you use this measure as a liquidity or perfor mance measure.  To the extent you use this
measure as a liquidity measure, explain to us how you determined it would be appropriate to disclose cash flow from operations per share considering the guidance in ASR 142.
Finally, as you filed your fina ncial statements and financia l review in a 6-K during the
current year, it appears that these measures w ould be subject to Item  10(e) of Regulation
S-K.  Tell us how you have considered this  guidance in preparing your current year
disclosures.
 Commercial Properties, page 31

2. In future periodic filings, pleas e define “in-place” rental rate s.  Also include quantitative
disclosure on the impact that tenant expe nse reimbursements and concessions, such as
free rent, have on average “in place” rents.
3. Please discuss in greater detail your leasing results for the prio r period.  In this regard, for
lease renewals, please discuss tenant impr ovements costs, leasing commissions and
tenant concessions.  Please pr ovide this disclosure on a pe r square foot basis.

Consolidated Financial Statements

 Consolidated Statements of Operations, page 97

4. Please explain to us how total revenues pres ented here reconciles to total revenues per
footnote 21 to the financial statements.
 Notes to Consolidated Financial Statements

 10. Investment Properties

5. We note your disclosure that certain adjustment s have been made to external valuations
conducted by third parties.  Please explain to us manageme nt’s rationale for adjusting
valuations done by third party ap praisers during the current year.

Brian Lawson Brookfield Asset Management June 24, 2011 Page 3

 We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requir e.  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 comments, please provi de a written statement from the company
acknowledging that:
 the company is responsible for the adequacy an d accuracy of the disclo sure in the filing;

 staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and

 the company may not assert staff comments as  a defense in any proceeding initiated by
the Commission or any person under the federa l securities laws of  the United States.

You may contact Robert Telewicz, Staff A ccountant at (202)551-3438 or the undersigned
at (202)551-3629 if you have quest ions regarding comments on the financial statements and
related matters.  Please cont act Kristina Aberg, Staff Attorney  at (202)551-3404 or Tom Kluck,
Legal Branch Chief at (202)551- 3233 with any other questions.

Sincerely,

 /s/ Tom Kluck for

Kevin Woody Accounting Branch Chief