UMH PROPERTIES, INC.
Juniper Business Plaza
3499 Route 9 North, Suite 3-C
Freehold, NJ 07728
(732) 577-9997
Fax: (732) 577-9980
VIA EDGAR
December 21, 2018
Ms. Shannon Sobotka
Staff Accountant
Division of Corporation Finance
Office of Real Estate and Commodities
U.S. Securities and Exchange Commission
Washington, D.C. 20549
| Re: | UMH PROPERTIES, INC. | |
| Form 10-K for the year ended December 31, 2017 | ||
| Form 8-K | ||
| Filed March 8, 2018 and November 1, 2018, respectively | ||
| File No. 001-12690 |
Dear Ms. Sobotka:
We are writing in response to your letter dated December 17, 2018 with respect to the above-referenced filing of UMH Properties, Inc. (the Company). Our response to your comment is as follows:
Form 8-K filed on November 1, 2018
General
1. In future filings please label FFO, Core FFO and Normalized FFO as attributable to common shareholders.
RESPONSE:
In future filings, UMH Properties, Inc. will label FFO, Core FFO and Normalized FFO as attributable to common shareholders.
Management acknowledges the following:
| ● | the Company is responsible for the adequacy and accuracy of the disclosure in the 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. |
If you have any questions or comments, please do not hesitate to contact me at 732-577-4033 or by email at achew@umh.com.
| Very truly yours, | |
| /s/ ANNA T. CHEW | |
| ANNA T. CHEW | |
| Vice President and Chief Financial Officer |
| cc: | Daniel Gordon SEC Division of Corporation Finance
Clare Cella Jonathan Zuckerman Ronald Martinez PKF O’Connor Davies, LLP |