SecProbe.io

September 16, 2024
Judy C. Gavant
Executive Vice President and Chief Financial Officer
Blue Ridge Bankshares, Inc.
1807 Seminole Trail
Charlottesville, VA 22901
Re:Blue Ridge Bankshares, Inc.
Form 10-K for fiscal year ended December 31, 2023
Form 10-Q for quarterly period ended June 30, 2024
File No. 001-39165
Dear Judy C. Gavant:
            We have reviewed your filing 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 fiscal year ended December 31, 2023
General
1.We note your disclosure on pages 2, 5, 14, 62 and 63 regarding the strategic and capital
plan, as well as the “BaaS winddown plan” that is an element of liquidity management.
We also note the discussion on page 63 regarding your plan to alleviate the substantial
doubt about your ability to continue as a going concern. Further, we note your press
release included as exhibit 99.1 to your Form 8-K dated April 30, 2024 about various
plans and their status, including a two-part critical action plan addressing regulatory
remediation efforts. In future periodic filings, please enhance your disclosures regarding
these various strategic, capital and winddown plans, including providing a more detailed
and robust discussion in Liquidity and Capital Resources regarding your remediation and
related plans and any actions that remain outstanding or ongoing.
Management's Discussion and Analysis of Financial Condition and Results of Operations
Loan Portfolio, page 41
We note the tabular disclosure on pages 41-42 detailing the composition of your gross 2.

September 16, 2024
Page 2
loan portfolio, which includes commercial real estate (“CRE”). Given the extent of CRE
in your loan portfolio, in future filings, please describe the specific details of any risk
management policies, procedures or other actions undertaken by management in response
to the current environment.
Deposits, page 48
3.In future filings, please address the items below with regards to your deposit disclosures.
•Noting that "core" deposits include various deposit types, clarify what is included in
non-core deposits.
•Enhance your narrative to provide more granularity regarding which change drivers
most impacted each deposit category.
4.We note your increased usage of brokered deposits and your dependence upon an
approved waiver to continue using them while a consent order is in place. In future
filings, please address the items below.
•Expand your disclosures, here or elsewhere, to discuss the level at which you expect
to maintain brokered deposits as well as any planned changes to deposit composition
as you transition away from banking as a service operations.
•Noting that brokered deposits appear to be time deposits and money market accounts,
quantify the amount in each category.
•If applicable, discuss any policies or internal limits regarding brokered deposit or
other deposit concentrations and whether you have complied with such internal
requirements.
Borrowings, page 49
5.We note your disclosure of FHLB and FRB borrowings. In future filings, please enhance
your narrative here to fulsomely tie quantitative changes to underlying drivers.
Liquidity, page 49
6.We note your disclosures regarding available sources of liquidity, including your tabular
disclosure regarding FHLB and FRB borrowings on page 49. In future filings, please
consider:
•adding tabular disclosure of all available sources of liquidity by type of borrowing
capacity ( e.g., Federal Home Loan Bank borrowings, FRB borrowing capacity, etc.),
with the table showing total borrowing capacity, less borrowings outstanding,
remaining capacity, and additional sources of liquidity ( e.g., cash, securities, etc.) to
arrive at total available liquidity; and
•discussing available sources of liquidity measured against levels of uninsured or total
deposits, to the extent that you consider this internally in managing your liquidity
levels.
Note 4. Loans and Allowance for Credit Losses, page 79
We note that you present gross loan information and credit quality information ( e.g., past
due information, risk grades, etc.) by loan category (Commercial and Industrial, Real
Estate – Construction, commercial, Real Estate – Construction, residential, Real Estate – 7.

September 16, 2024
Page 3
Mortgage, commercial, Real Estate – Mortgage, residential). We also note that you
disclose the allocation of Allowance for Credit Losses ("ACL") by these loan categories at
the end of the period on page 44. However, your disclosure of the ACL rollforward on
page 79 is presented only at the major loan segment ( i.e., Commercial and Consumer)
level. Please revise your disclosure, in future filings, to provide a rollforward by portfolio
segment, consistent with your loan category and other credit quality disclosures. Refer to
ASC 326-20-50-13.
Form 10-Q for quarterly period ended June 30, 2024
Item 2. Management's Discussion and Analysis of Financial Condition and Results of Operations
Private Placements, page 37
8.We note your disclosures here and in the footnotes regarding warrants issued as part of
your private placements, including that holders have an option for, but do not appear to be
compelled to use, cashless exercise. Please provide us with your accounting analysis
regarding balance sheet classification for the warrants. Include specific references to
authoritative guidance you relied upon in reaching your conclusions.
            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 Sarmad Makhdoom at 202-551-5776 or Cara Lubit at 202-551-5909 if you
have questions regarding comments on the financial statements and related matters. Please
contact John Stickel at 202-551-3324 or Todd Schiffman at 202-551-3491 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Finance