SecProbe.io

May 7, 2014

Via E -mail
Mr. Michael R. Cole
Chief Financial  Officer  and Treasurer
Universal Forest Products , Inc.
2801 East Beltline, NE
Grand Rapids, MI 49525

Re: Universal Forest Products , Inc.
  Form 10 -K
Filed February 26 , 2014
File No. 0-22684

Dear Mr. Cole :

We have reviewed your filing  and have the following comments.  In some of our
comments, we may ask you to provide us with information so we may better understand your
disclosure.

Please respond to this letter within ten business days by providing the requested
information, or by advising us when you will provide the requested response.   If you do not
believe our comments apply to your facts and circumstances, please te ll us why in your response.

After reviewing the information you provide in response to these  comments, we may
have  additional comments.

Form 10 -K for the year ended December 28, 2013

General

1. Please ensure that your risk factors fully describe the m aterial risks faced by you and
explain specifically how such risks are related to your business.   We note, for example,
that in your risk factor on page eight relating to economic and credit market conditions,
you state that you monitor your customers’ cre dit, but provide no elaboration, while in
your earnings call for the fourth quarter of the fiscal year of 2013 you note that many of
your customers are approaching their credit limits.   Similarly, in your risk factor
discussing fluctuations in the price of  lumber, you do not explain specifically how the
fluctuations in the lumber market have materially impacted your results of
operations.   These are just examples.   Please revise your risk factors accordingly in future
filings.

Mr. Michael R. Cole
Universal Forest Products , Inc.
May 7, 2014
Page 2

 Exhibit 13

Management’s Discussion and Analysis, page 3

Results of Operations, page 7

2. Multiple factors impacting the results of operations are cited throughout the discussion
and analysis of the segment reporting section beginning on page 14.  To the extent
practicable, please revise future filings to quantify the impact of each factor when
multiple factors are identified as impacting results of operations.  For example, disclosure
on page 15 lists factors which led to the increase in net sales for the Eastern and Western
report able segment in 2013 without quantification.  Also, you disclose on page 16 that
earnings from operations for the Site -Built reportable segment increased “primarily due
to an increase in unit sales and operating leverage on labor and overhead costs and an
easing of pricing pressure on sales.   In addition, the profits of our turn -key framing
operations were adversely impacted by an unexpected rise in labor costs early in the year
on certain projects, which offset some of the favorable impact of higher unit s ales and
pricing improvements.”  Refer to Item 303(a)(3) of Regulation S -K and Section 501.04 of
the FRC for guidance.

Proxy Statement Filed March 7, 2014

Executive Compensation, page 16

Annual Incentive Compensation, page 17

3. In future filings, please discuss how the compensation committee determined the
percentage of the relevant bonus pool to grant to each NEO.   Please also advise why the
ROI column in the chart on page 19 is blank.

We urge all persons who are responsible for the accuracy and adequac y of the disclosure
in the filing to be certain that the filing includes the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.   Since the company and its management are
in possession of all facts relating to a c ompany’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

 In responding to our comments, please provide  a written statement from the company
acknowledging that:

 the company is responsible for the adequa cy 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

Mr. Michael R. Cole
Universal Forest Products , Inc.
May 7, 2014
Page 3

  the company may not assert staff comments as a d efense in any proceeding initiated by
the Commission or any person under the federal securities laws of the United States.

You may contact Jenn Do at (202) 551-3743 , Nudrat Salik at (202) 551 -3692 , or me at
(202) 551 -3355  if you have questions regarding comments on the financial statements and
related matters.  Please contact Leland Benton  at (202) 551 -3791, or Erin Jaskot  at (202) 551 -
3442, with any other questions.

Sincerely,

 /s/ Terence O ’Brien

Terence O’Brien
Branch Chief