REITs

Company response: ASU 2023-07 updates ASC 280-10-50 and states that all public entities, including those public entities that have a single reportable segment, shall disclose certain information for which an income statement is presented including: ● Factors used to identify the public entity’s reportable segments, including the basis of organization, ● Types of products and services, and ● The title and position of the individual identified as the chief operating decision maker. Management views the Company as a single segment and has included the following in its quarterly filings on Form 10-Q. This was inadvertently not included in our Form 10-K. The following will be included in Note 1 of the Notes to… response letter →

Company response: The Company currently includes a tabular reconciliation from GAAP net income to FFO for each period presented for 2025 and 2024. However, we inadvertently did not include this reconciliation for the full year 2026 guidance. A NYSE Company: Symbol - UMH since 1968 The following table reconciles Net Income Attributable to Common Shareholders per share – fully diluted guidance to FFO Attributable to Common Shareholders per share - fully diluted guidance and Normalized FFO Attributable to Common Shareholders per share - fully diluted guidance: Full Year Guidance 2026 Net Income Attributable to Common Shareholders per share – fully diluted $0.06-$0.14 Depreciation $0.85 FFO Attributable to… response letter →

Company response: In our consideration of providing financial statements or summarized financial information for our equity method investments in our unconsolidated real estate ventures and Managed REITs, we evaluated and performed the requisite calculations pursuant to Rule 3-09 of Regulation S-X (“Rule 3-09”) and Rule 4-08(g) of Regulation S-X (“Rule 4-08(g)”). With respect to the Investment Test and Income Test required by Rule 3-09, we determined that none of our equity method investments were in excess of the 20% thresholds. Therefore, separate financial statements of the equity method investees were not required. Similarly, with respect to the Investment Test, Asset Test and Income Test, in accordance… response letter →

Company response: We acknowledge the Staff’s comment and confirm that in future filings, we will provide such reconciliations or, alternatively, if applicable, provide a statement that the information could not be presented without unreasonable efforts under Item 10(e)(1)(i)(B) of Regulation S-K, as applicable. response letter →

Company response: The Company respectfully advises the Staff that it carefully considered the disclosure requirements of ASC 280-10-50-22, 50-25, 50-26 and 50-30(c) in preparing the segment disclosures in Note 20 of the Form 10-K. As described below, the Company concluded that disclosure of total assets by reportable segment was not required because asset information is not included in the financial information regularly provided to the Company’s chief operating decision maker (“CODM”) for purposes of assessing segment performance or making resource allocation decisions. ​ ​ 4747 Bethesda Avenue, Suite 200, Bethesda, Maryland 20814 240.333.3600 jbgsmith.com ​ As disclosed in Note 20 of the Form 10-K, the… response letter →