SEC Company Response from UFP INDUSTRIES INC (UFPI) (CIK 0000912767) (UFPI) — Oct 6, 2015
UFP INDUSTRIES INC (UFPI) (CIK 0000912767)
Date: Oct. 6, 2015 · CIK: 0000912767 · Accession: 0000912767-15-000021
AI Filing Summary & Sentiment
Reasoning
Referenced dates: August 4, 2015, September 4, 2015
Letter
Division of Corporation Finance Securities and Exchange Commission Re: Universal Forest Products, Inc. Form 10-K Filed February 25, 2015 File No. 0-22684
Dear Ms. Rocha:
On behalf of Universal Forest Products, Inc., a Michigan corporation (the "Company"), we are responding to your most recent letter dated September 4, 2015, with respect to the above-referenced filing. The comments from your September 4, 2015, letter are set forth in bold font below and are followed by our response.
Form 10-Q for the period ended June 27, 2015
G. Segment Reporting, page 11
1.
We have read your response to comment 1 in our letter dated August 4, 2015. Please consider providing clarifying information included in your response in your future disclosures. We note, for example, the penultimate paragraph of your response appears to contain relevant and pertinent information necessary for an enhanced understanding of the change in management/ organization structure.
The Company will include, in future filings, information relevant to the manner in which the Company's reportable segments are identified as well as information that clarifies the most recent changes to its operating and reportable segments.
Attached to this letter is the Company's signed Acknowledgement to the above statements.
We hope that we have sufficiently responded to your comments. If you have additional questions or comments, please contact me directly.
Very truly yours,
VARNUM
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CORRESP 1 filename1.htm Document Bridgewater Place w Post Office Box 352 Grand Rapids, Michigan 49501-0352 Telephone 616 / 336-6000 w Fax 616 / 336-7000 w www.varnumlaw.com Michael G. Wooldridge Direct: 616 / 336-6903 mgwooldridge@varnumlaw.com October 6, 2015 Filed Via Edgar Ms. Melissa N. Rocha Senior Assistant Chief Accountant Division of Corporation Finance Securities and Exchange Commission Washington, D.C. 20549 Re: Universal Forest Products, Inc. Form 10-K Filed February 25, 2015 File No. 0-22684 Dear Ms. Rocha: On behalf of Universal Forest Products, Inc., a Michigan corporation (the "Company"), we are responding to your most recent letter dated September 4, 2015, with respect to the above-referenced filing. The comments from your September 4, 2015, letter are set forth in bold font below and are followed by our response. Form 10-Q for the period ended June 27, 2015 G. Segment Reporting, page 11 1. We have read your response to comment 1 in our letter dated August 4, 2015. Please consider providing clarifying information included in your response in your future disclosures. We note, for example, the penultimate paragraph of your response appears to contain relevant and pertinent information necessary for an enhanced understanding of the change in management/ organization structure. The Company will include, in future filings, information relevant to the manner in which the Company's reportable segments are identified as well as information that clarifies the most recent changes to its operating and reportable segments. Attached to this letter is the Company's signed Acknowledgement to the above statements. We hope that we have sufficiently responded to your comments. If you have additional questions or comments, please contact me directly. Very truly yours, VARNUM Michael G. Wooldridge MGW/jmn cc: Mr. Michael Cole, Chief Financial Officer 9817438_1 Grand Haven w Grand Rapids w Kalamazoo w Lansing w Metro Detroit Ms. Melissa N. Rocha October 6, 2015 Page 2 ACKNOWLEDGMENT We acknowledge the following: • The Company is responsible for the adequacy and accuracy of the disclosure in its filings; • SEC Staff comments or changes to disclosure in response to SEC Staff comments in the Company's filings reviewed by the SEC Staff do not foreclose the SEC from taking any action with respect to the Company's filings; and • The Company may not assert SEC staff comments as a defense in any proceeding initiated by the SEC or any person under the federal securities laws of the United States. October 6, 2015 /s/ Michael Cole Michael Cole, Chief Financial Officer, Universal Forest Products, Inc.