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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

May
4, 2026

Ms.
Kellie Kim

Mr.
Isaac Esquivel

Division
of Corporation Finance

Office
of Real Estate and Construction

U.S.
Securities and Exchange Commission

Washington,
D.C. 20549

  Re:
  UMH Properties, Inc.

  Form 10-K for the year ended December 31, 2025

  Form 8-K filed February 25, 2026

  File No. 001-12690

Dear
Ms. Kim and Mr. Esquivel:

UMH
Properties, Inc. (the “Company”) is submitting this letter in response to the comment letter dated April 29, 2026 from the
staff of the Securities and Exchange Commission (‘Staff”) with respect to the above-referenced filings. To facilitate the
Staff’s review, we have included the comment contained in the Comment Letter in bold text and have provided the Company’s
response immediately following the comment.

Form
10-K for the year ended December 31, 2025

Notes
to Consolidated Financial Statements

Note
1 - Organization, page 72

1. Please
                                            revise your financial statement footnote disclosures to provide all segment information required
                                            under ASU 2023-07 and ASC 280-10-50. We remind you that the guidance in ASC 280-10-50-20
                                            indicates that all public entities are subject to these disclosure requirements, including
                                            those with a single reportable segment.

Response:

ASU
2023-07 updates ASC 280-10-50 and states that all public entities, including those public entities that have a single reportable segment,
shall disclose certain information for which an income statement is presented including:

 ● Factors
                                            used to identify the public entity’s reportable segments, including the basis of organization,

 ● Types
                                            of products and services, and

 ● The
                                            title and position of the individual identified as the chief operating decision maker.

Management
views the Company as a single segment and has included the following in its quarterly filings on Form 10-Q. This was inadvertently not
included in our Form 10-K. The following will be included in Note 1 of the Notes to Consolidated Financial Statements and in Management’s
Discussion and Analysis of Financial Condition and Results of Operations in future filings:

“The
primary focus of our business is the ownership and operation of our manufactured home communities – leasing of manufactured homesites
and manufactured homes in our communities to residents. The sales of homes are integrated with the leasing of these manufactured homes
and homesites. Management views the Company’s business as a single segment based on its method of internal reporting in addition
to its allocation of capital and resources. Capital and resources are allocated to further the goal of maintaining and increasing occupancy
and net operating income in our communities. Our chief executive officer, with the assistance of our chief operating officer, is the
principal decision maker regarding allocation of resources. These decisions are based on the occupancy of the communities and community
net operating income, not based on the performance of home sales. Sales of homes are necessary to maintain and increase occupancy at
our communities. There are no longer dealers selling homes into our communities. We primarily order homes to fill vacant sites in the
communities. These homes are either rented or sold, based on the needs of the potential residents. Although certain components of the
sales operation are tracked (sales, cost of sales, etc.), separate discrete financial information for the entire sales operation is not
available. Most of the personnel costs, office expenses, maintenance and other expenses are borne by the community and cannot be allocated.
The components of the sales operation play no material role in decisions about resources to be allocated. Resources are allocated to
maintaining and increasing occupancy and net operating income in our communities.”

Additionally,
management will also discuss the principal changes in net income (loss) attributable to common shareholders in its Management’s
Discussion and Analysis of Financial Condition and Results of Operations in future filings.

Please
note that the above disclosures and discussions were incorporated in our most recent filing on Form 10-Q for the period ended March 31,
2026 filed on April 30, 2026.

Form
8-K filed February 25, 2026

General

2. In
                                            your earnings release, you disclose full year 2026 Guidance for normalized FFO per share
                                            without providing a reconciliation to the most directly comparable GAAP measure. Please include
                                            such reconciliation or, alternatively, provide a statement that the information could not
                                            be presented without unreasonable effort. Refer to Item 10(e)(1)(i)(B) of Regulation S-K
                                            and Questions 102.10(a) and 102.10(b) of the Corporation Finance Interpretations (“CFIs”)
                                            for Non GAAP Financial Measures.

Response:

The
Company currently includes a tabular reconciliation from GAAP net income to FFO for each period presented for 2025 and 2024. However,
we inadvertently did not include this reconciliation for the full year 2026 guidance.

A
NYSE Company: Symbol - UMH

since
1968

The
following table reconciles Net Income Attributable to Common Shareholders per share – fully diluted guidance to FFO Attributable
to Common Shareholders per share - fully diluted guidance and Normalized FFO Attributable to Common Shareholders per share - fully diluted
guidance:

    Full
    Year Guidance 2026

    Net
                                            Income Attributable to Common Shareholders per share – fully diluted

    $0.06-$0.14

    Depreciation

    $0.85

    FFO
                                            Attributable to Common Shareholders per share - fully diluted

    $0.91-$0.99

    Amortization
                                            of Financing Costs and Non- Recurring Other Expenses

    $.06

    Normalized
    FFO Attributable to Common Shareholders per share - fully diluted

    $0.97-$1.05

The
footnote disclosure in future filings will include this reconciliation for all periods presented, including periods for which guidance
is presented. Please note that guidance for full year 2026 was tightened as announced in our press release dated April 30, 2026 and included
in our Form 8-K filing on that date. The reconciliation was included as Footnote (3).

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:
    Ronald
                                            Martinez

    PKF
    O’Connor Davies, LLP

A
NYSE Company: Symbol - UMH

since
1968