SecProbe.io

August 4, 2015

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

Re: Universal Forest  Products, Inc.
  Form 10-K
Filed February 25 , 2015
File No. 0-2268 4

Dear Mr. Cole :

We have limited our review of your filing to the financial statements and related
disclosures 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 advise us as soon as possible when you will respond .  If you do not believe our
comment s apply to your facts and circumstances, please tell us why in your response.

After reviewing your response to these comment s, we may have  additional comments.

Form 10 -Q for the period ended June 27, 2015

G. Segment Reporting, page 11

1. We note the revised operating segments as of the first quarter of fiscal 2015 due to
“recent changes in management structure .” Please help us to better understand your new
segments by addressing the following:
 Explain the specific changes in your new management st ructure. Identify the
managers of each of the new segments. We note from page 30 of the proxy that
there appears to be named executives for only two of the three new segments;
 Disclose the nature and location of each material business/operation included in
each new reportable segment, including the All Other category; and
 Clarify which operations from your former Eastern, Western and Site -Built
segments constitute the new North, South and Western segments, including the
All Other category. In this regard, b ased on the information currently provided
and amounts reported in prior Forms 10 -Q, it does not appear that the new North

Mr. Michael R . Cole
Universal Forest  Products, Inc.
August 4, 2015
Page 2

 and South segments are simply the former Eastern segment broken out further by
region.

Management’s Discussion and Analysis, page 12

Liquidity and Capital Resources, page 19

2. Regarding inventories, we note the three -day increase in your first quarter of fiscal 2015
cash cycle compared to the first quarter of fiscal 2014, which further increased by an
additional day in your second quarter of fiscal 2015, the significant impact of inventories
on your operating cash flows and the CEO’s remarks in the earnings call transcript that
inventory is an area for improvement which you plan to bring in line with targets. We
also note significan t increases in accounts payable and the significant borrowing on your
revolving credit facility during fiscal 2015, although you state the increase in the revolver
is seasonal in nature. Please disclose the specific factors faced by management in
addressin g its growing inventories. In this regard, we note that seasonality, as suggested
by the CFO in his opening remarks of the earnings call transcript, may be only one such
factor. Please further explain the “weather” and “transportation challenges” the compa ny
is facing and how this is directly impacting inventory levels and how the company plans
to mitigate these challenges.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing i ncludes 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 company’s disclosure, they are responsible for the accuracy
and ad equacy 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 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 pers on under the federal securities laws of the United States.

Mr. Michael R . Cole
Universal Forest  Products, Inc.
August 4, 2015
Page 3

 You may contact Jenn Do at (202) 551-3743  or me at (202) 551 -3854  if you have
questions regarding comments on the financial statements and related matters.

Sincerely,

 /s/ Melissa N. Rocha

Melissa N. Rocha
Senior Assistant C hief Accountant