SEC Company Response from BROOKFIELD (BN) — Nov 23, 2011
BROOKFIELD Corp /ON/ (BN, BNH, BNJ, BKPA, BAMGF, BAMKF, BKAMF, BKFAF, BKFDF, BKFOF, BKFPF, BRCFF, BRFAF, BRFCF, BROXF) (CIK 0001001085)
Date: Nov. 23, 2011 · CIK: 0001001085 · Accession: 0001193125-11-321325
AI Filing Summary & Sentiment
Reasoning
Referenced dates: October 7, 2011
Letter
RE: Brookfield Asset Management Inc.
November 23, 2011
Division of Corporation Finance
U.S. Securities and Exchange Commission
100 F Street, NE
Washington, D.C. 20549
Attention: Kevin Woody and Robert Telewicz
Form 40-F
Filed March 31, 2011
Form 6-K
Filed March 24, 2011
File No. 033-97038
Thank you for your response to our letter dated October 7, 2011. For your reference we have included, along with our response, your question in italics, using the same numbering referencing in your letter.
Form 6-K filed March 24, 2011
Annual Report
Form 40-F
Five-Year Financial Review, page 13
1. We have considered your response to our prior comment one. We continue to believe that your Non-GAAP measure, as currently titled, does not comply with Item 10(e)(1)(ii)(E) of Regulation S-K. Please review your disclosure in future filings to fully comply with Item 10(e) of Regulation S-K.
Management will discontinue the use of the term “net operating cash flow” for its performance measure in future filings of Forms 6-K and 40-F.
In addition to the response above, we hereby acknowledge the following:
•
the company is responsible for the adequacy and accuracy of the disclosure in our 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 federal securities laws of the United States.
Should you have further questions, please contact the undersigned at (416) 359-8601.
Yours truly,
/s/ Brian D. Lawson
Brian D. Lawson
Chief Financial Officer
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CORRESP 1 filename1.htm CORRESP November 23, 2011 Division of Corporation Finance U.S. Securities and Exchange Commission 100 F Street, NE Washington, D.C. 20549 Attention: Kevin Woody and Robert Telewicz RE: Brookfield Asset Management Inc. Form 40-F Filed March 31, 2011 Form 6-K Filed March 24, 2011 File No. 033-97038 Thank you for your response to our letter dated October 7, 2011. For your reference we have included, along with our response, your question in italics, using the same numbering referencing in your letter. 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 prior comment one. We continue to believe that your Non-GAAP measure, as currently titled, does not comply with Item 10(e)(1)(ii)(E) of Regulation S-K. Please review your disclosure in future filings to fully comply with Item 10(e) of Regulation S-K. Management will discontinue the use of the term “net operating cash flow” for its performance measure in future filings of Forms 6-K and 40-F. In addition to the response above, we hereby acknowledge the following: • the company is responsible for the adequacy and accuracy of the disclosure in our 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 federal securities laws of the United States. Should you have further questions, please contact the undersigned at (416) 359-8601. Yours truly, /s/ Brian D. Lawson Brian D. Lawson Chief Financial Officer