United States securities and exchange commission logo
April 29, 2024
Michael R. Cole
Chief Financial Officer
UFP Industries, Inc
2801 East Beltline, N.E.
Grand Rapids, Michigan 49525
Re: UFP Industries, Inc
Form 10-K for the
Fiscal Year Ended December 31, 2023
Filed February 28,
2024
File No. 000-22684
Dear Michael R. Cole:
We have limited our review of your filing to the financial
statements and related
disclosures and have the following comments.
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 a
comment applies to your facts and circumstances, please tell us why in
your response.
After reviewing your
response to this letter, we may have additional comments.
Form 10-K for the Fiscal Year Ended December 31, 2023
Exhibit 13
Management's Discussion and Analysis of Financial Condition and Results
of Operations
Overview, page 3
1. We note your use of
"decremental operating margin" and "net surplus cash" within the
bullet points on page
3. To the extent these represent metrics or non-GAAP measures,
please revise to
provide all required disclosures to enable a reader to understand how these
were calculated or
determined.
Item 9A. Controls and Procedures
Evaluation of Disclosure Controls and Procedures, page 17
2. We note the disclosure
that you conducted an evaluation of your disclosure controls and
procedures; however,
you did not clearly disclose management s conclusions. In this
regard, please tell us
and revise your future filings to disclose
Michael R. Cole
UFP Industries, Inc
April 29, 2024
Page 2
management's conclusion on whether your disclosure controls and
procedures
were effective at the end of the period. Refer to the guidance in Item
307 of Regulation S-
K.
In closing, we remind you that the company and its management are
responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review,
comments, action or
absence of action by the staff.
Please contact Heather Clark at 202-551-3624 or Kevin Woody at
202-551-3629 with
any questions.
FirstName LastNameMichael R. Cole Sincerely,
Comapany NameUFP Industries, Inc
Division of
Corporation Finance
April 29, 2024 Page 2 Office of
Manufacturing
FirstName LastName