Brookfield Asset Management Pic Us, Llc

Allegations: DURING 2005-2012, A CURRENT EMPLOYEE OF THE REGISTRANT SERVED AS AN OFFICER OF TEGRA, A COMPANY THAT FOCUSES ON INVESTMENTS IN RESIDENTIAL REAL ESTATE IN BRAZIL. TEGRA IS NOT AN ADVISORY AFFILIATE OF THE REGISTRANT. THE CVM FINED THE EMPLOYEE (AND TWO OTHER OFFICERS OF TEGRA) FOR ALLEGED INCOMPLETE PUBLIC CORPORATE FILINGS MADE ON BEHALF OF TEGRA FOR THE YEARS 2010-2012. MORE SPECIFICALLY, THE CVM ALLEGED THAT THE FILINGS DID NOT DISCLOSE CERTAIN SUGGESTIONS FOR IMPROVEMENT MADE IN THE INDEPENDENT AUDITORS' REPORTS FOR THOSE YEARS REGARDING TEGRA'S INTERNAL CONTROL ENVIRONMENT. Status: Final Sanction Detail: MONETARY FINE OF R$50,000 (USD$13,000) Summary: THE CVM'S DECISION WAS TIMELY APPEALED ON A NUMBER OF GROUNDS, INCLUDING THAT THE INDEPENDENT AUDITORS' REPORTS FOR THOSE YEARS WERE ISSUED WITH NO QUALIFICATION AND THAT, IN TEGRA'S BELIEF, THE SUGGESTIONS MADE IN NO WAY COMPROMISED (OR COULD MATERIALLY COMPROMISE) THE RELIABILITY OF TEGRA'S FINANCIAL STATEMENTS. TEGRA'S MANAGEMENT HAS ALSO ASSURED THE CVM THAT IT IS TAKING INTO ACCOUNT THE SUGGESTIONS. AS A RESULT OF THE APPEAL, THE CVM DECREASED THE AMOUNT OF THE FINE FROM R$100,000 (USD $26,000) TO R$50,000 (USD$13,000).

Allegations: THE SECURITIES AND EXCHANGE BOARD OF INDIA ("SEBI") ALLEGED THAT: (1) PENBROOK CAPITAL ADVISORS PRIVATE LIMITED ("PENBROOK"), THE INVESTMENT MANAGER OF PENINSULA BROOKFIELD INDIA REAL ESTATE FUND (THE "FUND") AND A JOINT VENTURE BETWEEN (I) BROOKFIELD CAPITAL PARTNERS LTD (BERMUDA), A WHOLLY OWNED SUBSIDIARY OF BROOKFIELD ASSET MANAGEMENT INC., AND (II) PENINSULA LAND LTD, A THIRD-PARTY REAL ESTATE DEVELOPER); (2) THE CURRENT AND FORMER DIRECTORS OF PENBROOK, INCLUDING ANUJ RANJAN (FORMER DIRECTOR) AND SRIDHAR RENGAN (CURRENT DIRECTOR); AND (3) PENINSULA BROOKFIELD TRUSTEE PRIVATE LIMITED, (THE TRUSTEE OF THE FUND, HAVING THE SAME SHAREHOLDERS AS PENBROOK) ((1), (2) AND (3) COLLECTIVELY, THE "NOTICEES"), ACCEPTED IMPERMISSIBLY SMALL INVESTMENTS FROM CERTAIN INVESTORS IN THE FUND, FAILED TO MAINTAIN SUFFICIENTLY LARGE INVESTMENTS THEMSELVES IN THE FUND, AND EXTENDED THE TENURE OF THE FUND BEYOND THE PERMISSIBLE PERIOD, IN VIOLATION OF THE SECURITIES AND EXCHANGE BOARD OF INDIA ACT OF 1922 AND REGULATIONS FRAMED THEREUNDER (THE "SEBI ACT"). SEBI FURTHER ALLEGED THAT THE ANNUAL COMPLIANCE TEST REPORT FOR THE FUND DID NOT REFLECT THE NON-COMPLIANCE MATTERS ASSOCIATED WITH THE ALLEGED VIOLATIONS. Status: Final Sanction Detail: THE NOTICEES AGREED TO A TOTAL SETTLEMENT AMOUNT OF INR 8,500,000, OR APPROXIMATELY USD $114,865, WHICH WAS TIMELY PAID WITHOUT AN ADMISSION OR DENIAL OF GUILT. Summary: ON MARCH 19, 2021, THE NOTICEES RECEIVED A NOTICE FROM SEBI ALLEGING THAT THE NOTICEES ACCEPTED IMPERMISSIBLY SMALL INVESTMENTS FROM CERTAIN INVESTORS IN THE FUND, FAILED TO MAINTAIN SUFFICIENTLY LARGE INVESTMENTS THEMSELVES IN THE FUND, AND EXTENDED THE TENURE OF THE FUND BEYOND THE PERMISSIBLE PERIOD, IN VIOLATION OF THE SEBI ACT. THE NOTICE FURTHER ALLEGED THAT THE ANNUAL COMPLIANCE TEST REPORT FOR THE FUND DID NOT REFLECT THE NON-COMPLIANCES ASSOCIATED WITH THE ALLEGED VIOLATIONS. IN ORDER TO FULLY SETTLE THE PROCEEDING, THE NOTICEES AGREED TO PAY INR 8,500,000, OR APPROXIMATELY USD $114,865, WHICH WAS TIMELY PAID WITHOUT AN ADMISSION OR DENIAL OF GUILT.