SecProbe.io

February 8, 2013

Anna T. Chew
Vice President and Chief Financial Officer
UMH Properties, Inc.
Juniper Business Plaza
3499 Route 9 North, Suite 3C
Freehold, NJ  07728

Re: UMH Properties, Inc.
  Registration Statement on Form S-3
Filed  January 18, 2013
  File No.  333-186084

Dear Ms. Chew:

We have limited our review of your registration statement to those issues we have
addressed in our comments.  In  some of our comments, we may ask you to provide us with
information so we may better understand your disclosure.

Please respond to this letter by amending your registration statement and providing the
requested information .  Where you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.

After reviewing any amendment to your registration statement and the information you
provide in response to these  comments , we may have  additional comments.

Cover Page of the Prospectus

1. We note your statement that your securities are listed and traded on the New York Stock
Exchange.  Please identify the trading symbols for those securities on the cover page of
the prospec tus pursuant to Item 501(b)(4) of Regulation S -K.

Signatures, page 59

2. In your next amendment, please include the signature of your controller or principal
accounting officer.   Please refer to Instruction 1 to Form S -3.

We urge all persons who are respon sible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Act of 193 3 and
all applicable Securities  Act rules require.   Since the company and its management are in

Anna T. Chew
UMH Properties, Inc.
February 8, 2013
Page 2

 possession o f all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

Notwithstanding our comments, in the event you request acceleration of the effective date
of the pending registration s tatement please provide a written statement from the company
acknowledging that:

 should the Commission or the staff, acting pursuant to delegated authority, declare the
filing effective, it does not foreclose the Commission from taking any action with res pect
to the filing;

 the action of the Commission or the staff, acting pursuant to delegated authority, in
declaring the filing effective, does not relieve the company from its full responsibility for
the adequacy and accuracy of the disclosure in the filing; and

 the company  may not assert staff comments and the declaration of effectiveness as a
defense in any proceeding initiated by the Commission or any person under the federal
securities laws of the United States.

Please refer to Rules 460 and 461 regarding requests for  acceleration .  We will consider a
written request for acceleration of the effective date of the registration statement as confirmation
of the fact that those requesting acceleration are aware of their respective responsibilities under
the Securities Act o f 1933 and the Securities Exchange Act of 1934 as they relate to the proposed
public offering of the securities specified in the above registration statement.  Please allow
adequate time  for us to review any amendment prior to the requested effective date of the
registration statement.

Please contact Beth Frohlichstein  at (202) 551 -3789  or me at (202) 551 -3233 with any
other questions.

Sincerely,

 /s/ Tom Kluck

Tom Kluck
Branch Chief