SEC Comment Letter for UFP INDUSTRIES INC (UFPI) (CIK 0000912767) (UFPI) — Oct 14, 2009
UFP INDUSTRIES INC (UFPI) (CIK 0000912767)
Date: Oct. 14, 2009 · CIK: 0000912767 · Accession: 0000000000-09-057894
AI Filing Summary & Sentiment
Referenced dates: October 5, 2009, September 16, 2009
Letter
UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549-4631 DIVISION OF CORPORATION FINANCE October 14, 2009 By U.S. mail and facsimile to (616) 364-5558 Mr. Michael R. Cole, Chief Financial Officer Universal Forest Products, Inc. 2801 East Beltline, N.E. Grand Rapids, MI 49525 RE: Universal Forest Products, Inc. Definitive Proxy Statement on Schedule 14A filed March 6, 2009 File No. 0-22684
Dear Mr. Cole: We have reviewed your response letter dated October 5, 2009 and have the following additional comment. If you disagree , we will consider your explanation as to why our comment is inapplicable. We ma y ask you to provide us with supplemental information so we may better understand your disclosure. After reviewing this information, we may or may not raise additional comments. Definitive Proxy Statement Filed March 6, 2009
Executive Compensation, page 15
Compensation Discussion and Analysis, page 15
Compensation Program Components, page 16
Incentive Compensation, page 17
1. We note your responses to comment s seven and eight in our letter dated September 16, 2009. It remains unclear to us how you determined the non-equity incentive compensation awards receiv ed by your named executive officers. Please provide us with a materially comple te analysis of the process you used to determine the awards. In this regard, for illustrative purposes, it may be helpful to discuss and analyze in detail the calcula tion of the actual award received by one of your named executive officers. You should also specifically address in your response how you determined the percentage of the bonus pool allocated to each of your named executive officers. Please note that we may have additional comments based on your response.
Mr. Michael R. Cole Universal Forest Products, Inc. October 14, 2009 Page 2 * * * *
As appropriate, please respond to this comm ent within 10 business days or tell us when you will provide us with a response. Please furnish a letter that keys your response to our comment and provides any requested s upplemental information. Detailed response letters greatly facilitate our review. Pleas e file your response letter on EDGAR. Please understand that we may have additional comm ents after reviewing your response to our comment. Please contact Dieter King at (202) 551-3338 with any questions.
S i n c e r e l y , T e r e n c e O ’ B r i e n B r a n c h C h i e f
Show Raw Text
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-4631
DIVISION OF
CORPORATION FINANCE
October 14, 2009
By U.S. mail and facsimile to (616) 364-5558
Mr. Michael R. Cole, Chief Financial Officer Universal Forest Products, Inc. 2801 East Beltline, N.E. Grand Rapids, MI 49525
RE: Universal Forest Products, Inc.
Definitive Proxy Statement on Schedule 14A filed March 6, 2009
File No. 0-22684
Dear Mr. Cole:
We have reviewed your response letter dated October 5, 2009 and have the
following additional comment. If you disagree , we will consider your explanation as to
why our comment is inapplicable. We ma y ask you to provide us with supplemental
information so we may better understand your disclosure. After reviewing this
information, we may or may not raise additional comments. Definitive Proxy Statement Filed March 6, 2009
Executive Compensation, page 15
Compensation Discussion and Analysis, page 15
Compensation Program Components, page 16
Incentive Compensation, page 17
1. We note your responses to comment s seven and eight in our letter dated
September 16, 2009. It remains unclear to us how you determined the non-equity incentive compensation awards receiv ed by your named executive officers.
Please provide us with a materially comple te analysis of the process you used to
determine the awards. In this regard, for illustrative purposes, it may be helpful to discuss and analyze in detail the calcula tion of the actual award received by one
of your named executive officers. You should also specifically address in your
response how you determined the percentage of the bonus pool allocated to each
of your named executive officers. Please note that we may have additional comments based on your response.
Mr. Michael R. Cole
Universal Forest Products, Inc. October 14, 2009 Page 2
* * * *
As appropriate, please respond to this comm ent within 10 business days or tell us
when you will provide us with a response. Please furnish a letter that keys your response to our comment and provides any requested s upplemental information. Detailed response
letters greatly facilitate our review. Pleas e file your response letter on EDGAR. Please
understand that we may have additional comm ents after reviewing your response to our
comment.
Please contact Dieter King at (202) 551-3338 with any questions.
S i n c e r e l y , T e r e n c e O ’ B r i e n B r a n c h C h i e f