SEC Comment Letter for BROOKFIELD (BN) — Feb 22, 2017
BROOKFIELD Corp /ON/ (BN, BNH, BNJ, BKPA, BAMGF, BAMKF, BKAMF, BKFAF, BKFDF, BKFOF, BKFPF, BRCFF, BRFAF, BRFCF, BROXF) (CIK 0001001085)
Date: Feb. 22, 2017 · CIK: 0001001085 · Accession: 0000000000-17-006029
AI Filing Summary & Sentiment
Reasoning
Letter
Mailstop 3233 February 22, 2017 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 February 17, 2017 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 references to prior comments are to comments in our August 4 , 2016 letter .
FORM 40 -F FOR THE YEAR ENDED DECEMBER 31, 2015
Note 11 – Investment Properties & Note 12 – Property, Plant and Equipment
Brian D. Lawson Brookfield Asset Management, Inc. February 22, 2017 Page 2
1. We have considered your proposed disclosures in respon se to comment 1. Please address the following: a. Please also further adjust your disclosures of fair value and key valuation metrics within note 11 and note 12 to disaggregate this information by the same asset classes that you have identified in your p roposed sensitivity analysis. We believe such disaggregation to be consistent with the guidance outlined within paragraphs 93 and 94 of IFRS 13. b. We note your statement that “ sensitivity to reasonably likely changes in discount rates and terminal capi talization rates are quantitatively immaterial with respect to PP&E within the Infrastructure and Property segments.” Please confirm for us, if true, that a 25 basis point change to the relevant unobservable inputs for PP&E within Infrastructure and Proper ty segments is quantitatively immaterial.
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 February 22, 2017 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 February 17, 2017 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 references to prior comments are to comments in our August 4 , 2016 letter . FORM 40 -F FOR THE YEAR ENDED DECEMBER 31, 2015 Note 11 – Investment Properties & Note 12 – Property, Plant and Equipment Brian D. Lawson Brookfield Asset Management, Inc. February 22, 2017 Page 2 1. We have considered your proposed disclosures in respon se to comment 1. Please address the following: a. Please also further adjust your disclosures of fair value and key valuation metrics within note 11 and note 12 to disaggregate this information by the same asset classes that you have identified in your p roposed sensitivity analysis. We believe such disaggregation to be consistent with the guidance outlined within paragraphs 93 and 94 of IFRS 13. b. We note your statement that “ sensitivity to reasonably likely changes in discount rates and terminal capi talization rates are quantitatively immaterial with respect to PP&E within the Infrastructure and Property segments.” Please confirm for us, if true, that a 25 basis point change to the relevant unobservable inputs for PP&E within Infrastructure and Proper ty segments is quantitatively immaterial. 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