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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
8, 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

  Response
  dated May 4, 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 May 7, 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 the Financial Statements

Note
1 - Organization, page 72

1. 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 net operating income (“community NOI”), may be disclosed
                                            voluntarily. Refer to ASC280-10-50-28A, 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.

Response:

Management
views the Company as a single segment managed on a consolidated basis and will include the following in Note 1 of the Notes to Consolidated
Financial Statements in future filings, beginning with the Company’s Quarterly Report on Form 10-Q for the quarter ending June
30, 2026:

“The
Company reports segment information in accordance with ASC Topic 280, Segment Information (“ASC 280”). ASC 280 requires companies
to report financial and descriptive information for each identified operating segment based on management’s internal organizational
decision-making structure. Management has determined that the Company has one single reportable segment based on its method of internal
reporting in addition to its allocation of capital and resources. 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. Sales of homes are necessary to maintain and
increase occupancy at our communities. These leasing activities generate rental revenues and incur operating expenses. As each of the
Company’s assets has similar economic characteristics, the assets have been aggregated into one reportable segment. The accounting
policies for the reportable segment are the same as those described in Note 2 of the Notes to the audited Consolidated Financial Statements.
Our chief executive officer, with the assistance of our chief operating officer, is the Company’s Chief Operating Decision Maker
(“CODM”). The CODM is provided with the consolidated financial statements to assess segment performance and decide how to
allocate resources based on consolidated net income, which is reported on the Consolidated Statements of Income (Loss). The measure of
segment assets is reported on the Consolidated Balance Sheets as Total Assets. Total expenditures for additions to segment long-lived
assets are consistent with the amounts presented in the accompanying Consolidated Statements of Cash Flows. The CODM reviews net income
on an individual asset level and on a consolidated level and uses this information to monitor actual results, evaluate returns on assets
and determine how to reinvest profits. The revenue, costs and expenses, and net income for the reportable segment are the same as those
presented on the Consolidated Statements of Income (Loss). We report our results of operations consistent with the manner in which the
CODM reviews the business to assess performance and allocate resources.”

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