SecProbe.io

Mail Stop 4631
May 23, 2016

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

Re: Universal Forest Products, Inc.
  Form 10 -K
Filed February 24 , 2016
No. 0 -22684

Dear Mr. Cole:

We have reviewed  your filing an d have the following comments. We have limited our
review of your filing to the financial sta tements and related disclosures. 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 n ot believe our
comments apply to your facts and circumstances, please tell us why in your response.

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

Form 10 -K for the year ended December 26, 2015

Exhibit 13

Manageme nt’s Discussion and Analysis, page 3

Segment Reporting, page 9

1. In our letter dated May 7, 2014, we asked you to quantify the impact of each factor when
multiple factors are identified as impacting the results of operations, particularly at the
segment le vel. You indicated in your response dated May 14, 2014 , that you would
quantify, when practicable, the respective impact of multiple factors that meaningfully
impact the Company’s results of operations. We note your discussion and analysis on
pages 10 -11.  Please revise to disclose the underlying factors that have impacted net sales
and earnings from operations. For example, you explain that net sales in the North
segment increased due to “an increase in sales to our retail, residential construction and

Mr. Michael R. Cole
Universal Forest Products , Inc.
May 23, 2016
Page 2

 manufactured housing customers”, but based on your analysis by market, there is no
indication of how the markets fare in your geographic segments, or vice versa. Please
address whether quantitative data relating to sales prices, volume, lumber costs, etc. can
be provided by reportable segment and to the extent this information has materially
impacted operations, please disclose the impact of this information on operations in your
revised disclosure. Refer to Item 303(a)(3) of Regulation S -K and Section 501.04 of the
FRC for guidance.

Form 10 -Q for the period ended March 26, 2016

Management’s Discussion and Analysis, page 12

Liquidity and Capital Resources, page 18

2. In your letter dated August 27, 2015, you indicated, among other things, that you would
discuss the factors causing changes in inventory where practicable and, to the extent
material, identify and, if possible, quantify those primary factors, as well as th e
Company's efforts to mitigate their impact. In that response, you supplementally provided
further detail regarding inclement weather/seasonality and transportation challenges,
which factors you expressly referenced in your filings. For the first quarter of 2016, we
note the 7% increase in the inventory balance, which change also negatively and
materially impacted operating cash flows. However, you disclose herein that
“Improvements in our days supply of inventory in 2016 was due, in part, to strong
custom er demand and certain improvements in inventory management.” Please revise
your disclosure to quantify your days supply of inventory for the first quarter of 2016
compared to prior quarters and prior years days supply of inventory, explain any
significant differences in these ratios and explain to which market(s) and/or segment(s)
the “strong customer demand” is attributable and why.  Please also explain your basis in
the statement that certain improvements in inventory management have been made in
light of  the fact that your cash cycle was 50 days, 53 days and 54 days, for 2014, 2015
and the first quarter of 2016, respectively.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the fili ng 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 company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

Mr. Michael R. Cole
Universal Forest Products , Inc.
May 23, 2016
Page 3

 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 c omments 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 person under the federal securities laws of the United States.

You may contact Jenn Do at (202) 551-3743, or me a t (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  Chief Accountant
Office of Manufacturing and
Construction