SEC Comment Letter for BROOKFIELD (BN) — Aug 4, 2016
BROOKFIELD Corp /ON/ (BN, BNH, BNJ, BKPA, BAMGF, BAMKF, BKAMF, BKFAF, BKFDF, BKFOF, BKFPF, BRCFF, BRFAF, BRFCF, BROXF) (CIK 0001001085)
Date: Aug. 4, 2016 · CIK: 0001001085 · Accession: 0000000000-16-087191
AI Filing Summary & Sentiment
Reasoning
Letter
Mailstop 3233 August 4 , 2016 VIA E -MAIL Mr. Brian D. Lawson Chief Financial Officer Brookfield Asset Management, Inc. P.O. Box 762 Brookfield Place 181 Bay Street, Suite 300 Toronto, Ontario, Canada M5J 2T3
Re: Brookfield Asset Management, Inc. Form 40 -F for the year ended December 31, 2015 Filed March 31, 2016 File No. 033-97038
Dear Mr. Lawson:
We have reviewed your July 26 , 2016 response to our comment letter and have the following comment . In our comment , we may ask you to provide us with information so we may better understand your disclosure.
Please respond to this comment within ten busine ss days by providing the requested information or advis e us as soon as possible when you will respond. If you do not believe our comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this comment , we may have additional comments. Unless we note otherwise, our refere nces to prior comments are to comments in our July 12 , 2016 letter .
FORM 40 -F FOR THE YEAR ENDED DECEMBER 31, 2015
Financial Profile, page 28
Brian D. Lawson Brookfield Asset Management, Inc. August 4 , 2016 Page 2
1. We have considered your response to comment 1. Given the magnitude of investment properties and property, pla nt, and equipment to your balance sheet, the inherent uncertainty related to the underlying Level 3 unobservable inputs utilized to determine fair value coupled with the fact that fair value changes represent a material portion of your net income, we conti nue to believe inclusion of a sensitivity analysis of material assumptions based on reasonably likely changes would be appropriate. Please revise future filings and provide an example of your proposed disclosures.
You may contact Wilson K. Lee at (202) 551 - 3468 or me at (202) 551 - 3295 if you have any questions.
Sincerely,
/s/ Jennifer Monick
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Mailstop 3233 August 4 , 2016 VIA E -MAIL Mr. Brian D. Lawson Chief Financial Officer Brookfield Asset Management, Inc. P.O. Box 762 Brookfield Place 181 Bay Street, Suite 300 Toronto, Ontario, Canada M5J 2T3 Re: Brookfield Asset Management, Inc. Form 40 -F for the year ended December 31, 2015 Filed March 31, 2016 File No. 033-97038 Dear Mr. Lawson: We have reviewed your July 26 , 2016 response to our comment letter and have the following comment . In our comment , we may ask you to provide us with information so we may better understand your disclosure. Please respond to this comment within ten busine ss days by providing the requested information or advis e us as soon as possible when you will respond. If you do not believe our comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment , we may have additional comments. Unless we note otherwise, our refere nces to prior comments are to comments in our July 12 , 2016 letter . FORM 40 -F FOR THE YEAR ENDED DECEMBER 31, 2015 Financial Profile, page 28 Brian D. Lawson Brookfield Asset Management, Inc. August 4 , 2016 Page 2 1. We have considered your response to comment 1. Given the magnitude of investment properties and property, pla nt, and equipment to your balance sheet, the inherent uncertainty related to the underlying Level 3 unobservable inputs utilized to determine fair value coupled with the fact that fair value changes represent a material portion of your net income, we conti nue to believe inclusion of a sensitivity analysis of material assumptions based on reasonably likely changes would be appropriate. Please revise future filings and provide an example of your proposed disclosures. You may contact Wilson K. Lee at (202) 551 - 3468 or me at (202) 551 - 3295 if you have any questions. Sincerely, /s/ Jennifer Monick Jennifer Monick Assistant Chief Accountant Office of Real Estate and Commodities