July 10, 2025
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 28, 2024
Filed February 26, 2025
Form 8-K Furnished April 28, 2025
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.
July 10, 2025
Page 2
Form 10-K for the Fiscal Year Ended December 28, 2024
Item 9A. Controls and Procedures
Evaluation of Disclosure Controls and Procedures, page 70
1. We note your response dated May 10, 2024 to our comment letter from our
prior
review stating you will include and disclose management's conclusions as
to the
effectiveness of your disclosure controls and procedures. We also note
your Form 10-
Q filed May 7, 2025 discloses management's conclusions. However, the
change was
not reflected in this filing. Please tell us and amend you filing to
disclose
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.
Form 8-K Furnished April 28, 2025
Exhibit 99(a), page 7
2. Your presentation on pages 7 and 8 gives the appearance of a full
non-GAAP income
statement. Please note that the presentation of a full non-GAAP income
statement, or
a presentation that gives the appearance of one, may place undue
prominence on the
non-GAAP information and give the impression that the non-GAAP income
statement
represents a comprehensive basis of accounting. Confirm to us that you
will not
present full non-GAAP consolidated income statements or their
equivalents in future
filings. Refer to Question 102.10(c) of the C&DI's on Non-GAAP Financial
Measures.
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 Stephany Yang at 202-551-3167 or Kevin Woody at
202-551-3629
with any questions.
Sincerely,
Division of
Corporation Finance
Office of
Manufacturing