UMH PROPERTIES, INC. (UMH, UMH-PD) – SEC staff letter

Staff comment: We note from your response to our prior comment 1 that management views the company as a single segment. Please clarify if this single segment is managed on a consolidated basis. If you determine the company has a single segment that is managed on a consolidated basis, please revise your disclosure to report consolidated net income or loss, as reported on your consolidated statement of income (loss), as the required measure of segment profit or loss or tell us how you determined it was not the measure required to be disclosed. Note that if the chief operating decision makers ("CODMs") use more than one measure of segment profit or loss, the measure required to be disclosed shall be that… letter →