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SEC Company Response from UMH PROPERTIES, INC. (UMH, UMH-PD) (CIK 0000752642) (UMH) — Dec 21, 2018

UMH PROPERTIES, INC. (UMH, UMH-PD) (CIK 0000752642)
Date: Dec. 21, 2018 · CIK: 0000752642 · Accession: 0001493152-18-017850

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File numbers found in text: 001-12690

Referenced dates: December 17, 2018

Date
Dec. 21, 2018
Author
/s/ ANNA T. CHEW
Form
CORRESP
Company
UMH PROPERTIES, INC. (UMH, UMH-PD) (CIK 0000752642)

Letter

VIA EDGAR Division of Corporation Finance Office of Real Estate and Commodities 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

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CORRESP
1
filename1.htm

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