SecProbe.io

November 9, 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 response letter da ted October 7, 2011 and have the following
additional comment.  In our comment, 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 may ha ve additional comments.

Brian Lawson Brookfield Asset Management November 9, 2011 Page 2

Form 6-K filed March 24, 2011

 2010 Annual Report

 Form 40-F

 Five-Year Financial Review, page 13

1. We have considered your response to our pr ior comment one.  We continue to believe
that your Non-GAAP measure, as currentl y titled, does not comply with Item
10(e)1(ii)(E) of Regulation S-K.  Please revise your disclosure in fu ture filings to fully
comply with Item 10(e) of Regulation S-K.  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 questions.
Sincerely,
   /s/ Kevin Woody
Kevin Woody Accounting Branch Chief