SecProbe.io

September 30 , 2014

VIA E -Mail
Mr. Brian D. Lawson
Chief Financial Officer
Brookfield Asset Management, Inc.
Brookfield Place
P.O. Box 762
181 Bay Street, Suite 330
Toronto, Ontario, Canada M5J 2T3

Re: Brookfield Asset Management, Inc.
  Form 40 -F for the year ended December  31, 2013
Filed on March 31, 2014
File No.  033-97038

Dear Mr. Lawson :

We have reviewed your filings and have the following com ments. 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 providing the requested
information or by advising us when you will provid e the requested response. If you do not
believe our comments apply to your facts and circumstances, please tell us why in your response.

 After reviewing the information you provide in response to these comments, we may
have additional comments.

FORM 40 -F FOR THE YEAR ENDED DECEMBER 31, 2013

Exhibit 99.2

Note 3 – Segmented Information, pages 102 – 108

1. We have considered your responses to comments 10 and 12 in your correspondence dated
March 13, 2014.   You have identified corporate operations as a sep arate operating
segment.   It is not clear how corporate operations meet the definition of an operating
segment under IFRS 8.   Please tell us how you evaluated the guidance outlined in
paragraphs 5 through 10 of IFRS 8 in determining that corporate operat ions meets the
definition of an operating segment.   Specifically, please explain what revenues are

Mr. Brian D. Lawson
Brookfield Asset Management, Inc.
September 30 , 2014
Page 2

 generated through your corporate operations and how they are not incidental to the
activities of your operations as a whole.

Note 30 – Related Party Transactions, page 144

2. Please clarify whether Partners Limited incurs any expenses (i.e. payment of services for
your benefit or provides compensation to any current executives and directors) on your
behalf.   To the extent such transactions exist, please  clarify how it is accounted for and
where such transactions are reflected on your IFRS financial statements.

Form 6 -K FILED ON APRIL 7, 2014

Exhibit 99.1

3. We note your disclosure on page 14 that the total value of shares, DSUs and RSUs
beneficially owne d, controlled or directed by Mr. Flatt in 2014 is $754,283,225 and your
disclosure on page 41 that the value of his total cumulative compensation from 2002 to
2013 was $88,947,200 at December 31, 2013.   Please tell us why these amounts are
significantly di fferent.   In addition, please quantify any amounts received by each of your
named executive officers and directors resulting from their ownership, directly or
indirectly, in Partners Limited and/or its affiliates.

4. We note your disclosure on pages 4 and 5 regarding the principal holders of voting
shares.   Please tell us whether Partners Limited and/or its affiliates continue to acquire or
dispose of any Class A or Class B shares, and, if so, please describe how Partners
Limited and/or its affiliates acquire  or dispose of shares, including how any decisions to
acquire or dispose of shares are made.

  We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information t he Securities Exchange Act of
1934 and all applicable Exchange Act rules require. 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 provide a written statement from the company
acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosure in the filings;

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

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

Mr. Brian D. Lawson
Brookfield Asset Management, Inc.
September 30 , 2014
Page 3

You may contact Wilson K. Lee at (202 ) 551 -3468 or me at (202) 551 -3693  if you have
questions regarding comments on the financial statements and related matters.  Please contact
Folake Ay oola at (202) 551 -3673 or Jennifer  Gowetski at (202) 551 -3401 with any other
questions.

                                                                     Sincerely,

  /s/ Eric McPhee

         Eric McPhee
         Senior Accountant