SecProbe.io

Mail Stop 3010
       February 25, 2010

Via U.S. Mail and Fax (732) 577-9980

Ms. Anna T. Chew
Chief Financial Officer UMH Properties, Inc. Juniper Business Plaza, 3499 Route 9 North, Suite 3-C Freehold, NJ    07728   RE:  UMH Properties, Inc.
Form 10-K for the period  ended December 31, 2008
  Filed March 10, 2009   File No. 1-12690

Dear Ms. Chew:
We have reviewed your response letter  dated January 11, 2010 and have the
following additional comments.  In our comments, we ask you to provide us with
information so we may better understand your  disclosure.  After reviewing this
information, we may raise additional comments.
Please understand that the purpose of our re view process is to assist you in your
compliance with the applicable disclosure requirements and to enhance the overall disclosure in your filing.  We look forward to  working with you in these respects.  We
welcome any questions you may have about our  comments or on any other aspect of our
review.  Feel free to call us at the telephone numbers listed at the end of this letter.

Consolidated Statements of Income, page 52

1. We note your response to comment 2.  In future filings, plea se present amounts
earned from dividends, interest on securitie s, profits or losse s on securities and
miscellaneous other income or deduc tions below operating expenses in
accordance with Rule 5-03 of Regulation S-X.

Note 4 – Securities Available for Sale, page 61
2. Your responses to prior comments 4 & 5 indicate that you review securities for
other than temporary impairment if the fa ir value is below cost by 20% and that a
sharp decrease in the REIT market in 2009 resulted in you reviewing securities

UMH Properties, Inc.
February 25, 2010 Page 2
for other than temporary impairment that  had not been reviewed before despite
being in an unrealized loss position for more than 6 months.  Since the guidance
of ASC 320-10-35 does not provi de a quantitative thresh old regarding when to
review for impairment, please clarify to us how you determined that it was
appropriate to not test for other than temporary impairme nt if a security was less
than 20% below cost.  In addition, please qua ntify the value of s ecurities that have
not been evaluated for other than temporary impairment in future filings.

You may contact William Demarest, Sta ff Accountant at 202-551-3432 or me at
202-551-3429 if you have questions regarding co mments on the financial statements and
related matters.  Please contact Jerard Gibson, Staff Attorney at 202-551-3473 with any
other questions.
Sincerely,

Kristi Marrone  Staff Accountant