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CORRESP
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CORRESP

 October 7, 2013

Division of Corporation Finance

 U. S. Securities and Exchange
Commission

 100 F Street, NE

 Washington, D.C. 20549

Attention: Jessica Barberich

RE:
Brookfield Asset Management, Inc.

 Form 40-F for the year ended December 31, 2012

Filed on April 2, 2013

 File
No. 033-97038

 Thank you for your letter dated September 3, 2013. For your reference we have included, along with our responses, each of your
questions in italics using the same numbering references in your letter.

 FORM 40-F FOR THE YEAR ENDED DECEMBER 31, 2012

Exhibit 99.2

 Part 1 – Overview and Outlook

 Consolidated Financial Information, page 19

1.
You indicate that a large variance in revenues within a business that is largely owned by non-controlling interests may have a relatively small impact on net income attributable to shareholders. Please clarify this
statement to us and describe in more detail why this would be the case.

 Brookfield’s consolidated financial statements include the
results of a number of partially owned entities. The company’s consolidated revenues reflect 100% of any variance in revenues of a consolidated partially owned entity, while a portion of the corresponding variance in net income is attributed to
non-controlling interests. The resulting net income attributable to Brookfield shareholders only reflects the remaining portion of any variance in the consolidated entity’s net income.

 Part 3 – Business Segment Results

Segment Operating and Performance Measures, pages 34 - 36

2.
We continue to question your presentation and discussion of non-IFRS measures. Although you identify several measures as non-IFRS on pages 34-36, you have co-mingled your discussion of the non-IFRS measures with your
IFRS segment profit/(loss) measures in your segment discussion. Please revise your segment discussion to separately discuss the results of all of your segments first on an IFRS basis (e.g., FFO) and then, to the extent you continue to disclose the
non-IFRS measures (e.g., net operating income and segment operating income), on a non-IFRS basis. Your current presentation does not adequately separate and identify the measures and provides undue prominence to the non-IFRS measures.

 The company’s key measure of financial performance is Funds from Operations (“FFO”), as noted on pages 34 and 102 of its
December 31, 2012 Form 40-F. To assist users in their understanding of the company’s financial performance, the company discloses the components of FFO throughout its segment discussion.

The company identifies on page 35 of Form 40-F that two components of FFO, Net Operating Income (“NOI”) and Segment Operating Income
(“SOI”), are non-IFRS measures. The company includes these measures as it believes they are useful in assisting readers’ understanding of changes in a business segment’s FFO.

To the extent the company continues to disclose non-IFRS measures in future filings, these measures will be separated and clearly labeled as such, with IFRS
measures given prominence.

3.
For some of the measures identified as non-IFRS measures, we note you have referenced readers to the reconciliations provided within Note 3. To the extent you continue to present and discuss non-IFRS measures, please
revise to present the related reconciliations alongside such discussion instead of referencing to footnote disclosures which should be presented in accordance with IFRS requirements. Also, clarify why your footnotes include non-IFRS measures.

 On page 35 of Form 40-F, the company incorrectly noted that it reconciled NOI and SOI to “revenues in Note 3 of our consolidated
financial statements.” The company will remove the incorrect reference in future filings of Form 40-F.

 The company reconciled both NOI and SOI to
revenues on page 39 of form 40-F, immediately following the presentation of the non-IFRS measures on page 37. Furthermore, as both measures are components of FFO, they can be reconciled to FFO using the table on page 37.

The company does not utilize non-IFRS measures in the notes to its consolidated financial statements.

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4.
Please further clarify to us the basis for your FFO definition. Specifically, explain your basis for inclusion of disposition gains that are not otherwise included in net income as determined under IFRS. In
particular, explain why management believes it is useful to investors to include the fair value changes and revaluation surplus recorded in prior periods when assessing the financial performance of the company and its segments in the current period.
It does not appear that the definition of FFO would include amounts that are not recorded in the latest year’s financial statements.

The company’s chief operating decision maker uses FFO as defined by the company to assess the company’s investment performance across all asset
classes or segments. As stated on page 34 of the company’s Form 40-F, disposition gains are included because the purchase and sale of assets is a normal part of the company’s business. The company’s definition of FFO includes
previously recorded revaluation amounts, when calculating disposition gains or losses, in order to assess performance over the full life of an investment. IFRS net income, on the other hand, only includes certain fair value adjustments, with others
recorded directly in equity depending on the nature of the asset. The Company’s definition of FFO is consistent in the manner disposition gains or losses are calculated, regardless of asset class, and accordingly, this presentation is additive
to the presentation of IFRS net income.

 Further clarification is included within financial statement Note 3 (page 104), which states that
“disposition gains include gains and losses recorded in net income arising from transactions during the current year adjusted to include fair value changes and revaluation surplus recorded in prior periods. Disposition gains also include
amounts that are recorded directly in equity as changes in ownership as opposed to net income because they result from a change in ownership of a consolidated entity.”

5.
We note you have reconciled net operating income and segment operating income to revenues. It appears that net income is the most comparable measure to net operating and segment operating income, not revenue. Please
revise or explain your basis for determining that revenue was the most comparable measure calculated in accordance to IFRS instead of net income.

The company believes that revenue is the most comparable measure to NOI and SOI because there are fewer reconciling line items between NOI and SOI and revenue
than there are to net income.

 As noted in our response to question 3 above, both measures are components of FFO and can be reconciled to FFO using the
table on page 37, and can be further reconciled in aggregate to net income on page 38.

6.
Since you include a discussion and analysis of your segment performance measures as determined under IFRS 8, you should also include a complete discussion of the reconciling items that are not included in each of the
segment performance measures. Please revise to provide discussion and analysis of the reconciling items that apply to each particular segment being discussed.

Previously the company has discussed the results of all of the material items included in the Corporate/Unallocated column in section 4 of
its December 31, 2012 MD&A - Capitalization and Liquidity.

 In future filings the company will include a summary discussion and analysis of these
results and reconciling items in Section 3.

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7.
We note your disclosure of “net invested capital” when discussing your office development, opportunity and finance and when discussing your portfolio valuation of your renewable energy segment. Please
clarify how you define this term, how it is used by management to assess your financial condition and/or performance, and how these amounts relate to your IFRS financial statements.

The company incorrectly included the term “net invested capital” in two instances in Form 40-F, when it intended to use the term “common equity
by segment.”

 Future filings will exclude all references to the term “net invested capital”.

Asset Management and Other Services, pages 39 – 43

8.
We note that you have presented annualized amounts alongside your presentation of results of operations accounted for under IFRS. Please revise to present such information separately from your results of operations
accounted for under IFRS. As a part of your revised disclosures, please discuss the importance of providing such information to investors and how management utilizes this information in assessing and monitoring performance. Also, tell us and
disclose how you calculate the annualized amounts.

 In future filings the company will clearly label this measure as non-IFRS and
provide a discussion of the importance of this measure and how management utilizes this information in assessing and monitoring performance.

 The method
in which asset management revenues are determined is described on page 36 of Form 40-F. Annualized asset management revenues is determined using a consistent methodology as asset management revenue; It is based on the fee bearing capital under
management at period end multiplied by the contractual percentage fee for managing those assets.

9.
Please expand your disclosure to also note the amount of asset management and other fees that are eliminated in consolidation.

Asset management revenues earned within consolidated entities are disclosed in Note 3(c) to the financial statements as this is an adjustment made in forming
the company’s operating segments.

 Property, page 43

The company historically included additional information in its MD&A on its property operations in order to facilitate users understanding of this
business, particularly as part of the business was held through a reporting issuer (Brookfield Office Properties) and a significant portion was held privately. With the formation of Brookfield Property Partners LP, virtually all of the
company’s property operations will be held by a separate reporting issuer and therefore disclosing this information within the company’s Form 40-F may be redundant except to the extent it is considered material to the company.

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10.
In future Exchange Act reports, please revise to provide more detail regarding the geographic diversification and tenant concentration of your portfolio. In addition, please revise to clarify the portion of your
portfolio that is fully consolidated on your balance sheets and the portion that is accounted for using the equity method of accounting.

The company will include this information to the extent it is material in the context of the company’s consolidated financial statements.

11.
We note your disclosure on page 44 that you completed the development of the 1 million square foot Brookfield Place office tower in Perth and advanced work on 6 million square feet of office development
projects. In future Exchange Act reports, for material developments, please revise your disclosure to provide the completion date, costs incurred to date and budgeted costs. For completed developments, please disclose costs per square foot,
including whether leasing costs are included.

 We will comply.

12.
We note that leases representing 10.3% and 10.7% are expiring in 2013 for your office and retail properties, respectively. In future Exchange Act reports, please revise, here or elsewhere, as applicable, to include a
more detailed discussion of leasing activity during the reporting period and provide a roll forward of beginning of year vacant space to end of year vacant space with disclosure of new space that became vacant during the period and all space filled
during the period, including new and renewed leases. In addition, please disclose leasing costs, such as tenant improvements and leasing commissions for both new leases and renewals on a per square foot basis. With respect to new and renewed leases,
please provide quantitative disclosure comparing the average base rent per square foot on expiring leases with rates on new and renewed leases.

The company will include this information to the extent it is material in the context of the company’s consolidated financial statements.

13.
We note your disclosure in the tables on pages 46 and 47 with respect to expiring leases for your office and retail properties. In future Exchange Act reports, please revise to provide the annual rental and gross
annual rental represented by such expiring leases. In addition, please discuss the relationship between market rents and expiring rents.

The company will include this information to the extent it is material in the context of the company’s consolidated financial statements.

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 Office Properties, page 45

14.
We note your disclosure on page 46 with respect to the strong credit quality of your tenants and that you direct special attention to credit quality to ensure the long-term sustainability of rental revenues through
economic cycles. In future Exchange Act reports, please revise to describe how you monitor tenant credit quality.

 The company will
include this information to the extent it is material in the context of the company’s consolidated financial statements.

 Retail Properties, page
47

15.
We note your disclosure on page 45 with respect to the period to period changes in same store performance for your office properties. In future Exchange Act reports, for your retail properties, please revise to
discuss period to period changes in same store performance and within same store, please address the relative impact of occupancy and rent rate changes.

The company included the analysis on page 45 with respect to its office portfolio to assist readers in understanding period-over-period changes in
consolidated operations. The majority of the Company’s retail operations are held through equity-accounted investments, primarily General Growth Properties Inc. (“GGP”), which is a separate SEC registrant. The results of the
company’s equity accounted income in GGP are discussed in detail on page 47 of Form 40-F in a manner meant to be consistent with GGP’s public disclosures.

The company will consider including a same store analysis on its consolidated retail business line operations in the future, to the extent those results
become material.

 Renewable Power, page 49

16.
We note your disclosure on page 52 that your wholly-owned energy marketing group has entered into purchase agreements and price guarantees with Brookfield Renewable that fix the prices for most of the North American
hydroelectric generation that is not already sold under a long-term contract. In future Exchange Act reports, please revise to provide more detailed disclosure regarding these agreements and how they impact your business operations and revenues. In
addition, please clarify to explain how the majority of these arrangements are offset by you with long-term contracts.

 We will comply.

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 Part 4 – Capitalization and Liquidity

Debt to Capitalization, pages 65 – 66

17.
We note that your inclusion of accounts payable and other liabilities and deferred income taxes within your capitalization definition is consistent with how you assess your leverage ratios and how you present them to
your rating agencies. Please clarify for us and revise your disclosure to further discuss your basis for including such amounts as capitalization. Also, please highlight that their inclusion may cause your calculation to not be comparable to ratios
of other companies.

 On page 65 of Form 40-F, the company defines capitalization to include “accounts payable and other liabilities
and deferred income taxes, as well as borrowings, capital securities, interests of others in consolidated funds and equity, which is consistent with how we assess our leverage ratios and how we present them to our rating agencies