SEC Comment Letter 0000000000-26-004669 to UMH PROPERTIES, INC. (UMH)
UMH PROPERTIES, INC.
Date: May 7, 2026 · CIK: 0000752642 · Accession: 0000000000-26-004669
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File numbers found in text: 001-12690
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May 7, 2026
Anna T. Chew
Chief Financial Officer
UMH Properties, Inc.
3499 Route 9 North, Suite 3-C
Freehold, NJ 07728
Re: UMH Properties, Inc.
Form 10-K for the Year Ended December 31, 2025
Response dated May 4, 2026
File No. 001-12690
Dear Anna T. Chew:
We have reviewed your May 4, 2026 response to our comment letter and have the
following comment.
Please respond to this letter by providing the requested information or advise us as soon
as possible when you will respond. If you do not believe a comment applies to your facts and
circumstances, please tell us why in your response.
After reviewing your response to this letter, we may have additional comments. Unless
we note otherwise, any references to prior comments are to comments in our April 29,
2026 letter.
Form 10-K for the Year Ended December 31, 2025
Notes to the Financial Statements
Note 1 - Organization, page 72
We note from your response to our prior comment 1 that management views the
company as a single segment. Please clarify if this single segment is managed on a
consolidated basis. If you determine the company has a single segment that is managed
on a consolidated basis, please revise your disclosure to report consolidated net income
or loss, as reported on your consolidated statement of income (loss), as the required
measure of segment profit or loss or tell us how you determined it was not the measure
required to be disclosed. Note that if the chief operating decision makers ("CODMs") use
more than one measure of segment profit or loss, the measure required to be disclosed
shall be that which is determined in accordance with the measurement principles most
consistent with those used in measuring the corresponding amounts in the consolidated
financial statements. Additional measures of segment profit or loss, such as community 1.
May 7, 2026
Page 2
net operating income ("community NOI"), may be disclosed voluntarily. Refer to ASC
280-10-50-28A, 50-28C and 55-15F. In addition, please revise to provide the following
disclosures, if applicable:
•Disclose the significant expense categories and amounts that are regularly provided
to the CODMs and included in each reported segment profit or loss pursuant to ASC
280-10-50-26A;
•An explanation of the measurements of segment profit or loss and segment assets,
and the reporting provided to the chief operating decision makers pursuant to ASC
280-10-50-29; and,
•If an additional measure of segment profit or loss (i.e., community NOI) is
voluntarily disclosed, please provide the reconciliations pursuant to ASC 280-10-50-
30.
Please direct any questions to Kellie Kim at (202) 551-3129 or Isaac Esquivel at (202)
551-3395.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction