SecProbe.io

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                                          August 19, 2005

Division of Corporation Finance
Securities and Exchange Commission
Mail Stop 4561
450 Fifth Street, N.W.
Washington, DC 20549

Attn: Mr. Don Walker
      Senior Assistant Chief Accountant

                             Re: Exchange National Bancshares, Inc.
                                 Form 10-K for the year ended December 31, 2004
                                 SEC File No. 000-23636

Dear Mr. Walker:

            We are writing in response to your letter dated August 9, 2005, with
respect to the above-referenced report filed by Exchange National Bancshares,
Inc. (the "Company"). Our numbered responses to your comments correspond to the
numbered comments in your letter.(1)

            In responding to your comments, we acknowledge that:

                  -     the Company is responsible for the adequacy and accuracy
                        of the disclosure in our filing with the Commission;

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(1)   A complete response to the numbered comments in your letter would call for
      the disclosure of information that is covered by one or more exemptions in
      the Freedom of Information Act. In particular, 17 C.F.R. Section
      200.80(b)(4) exempts disclosure of trade secrets and commercial or
      financial information which are privileged or confidential. In accordance
      with the Freedom of Information Act, the privileged or confidential
      information has been omitted from this response letter and is being
      furnished to the Office of Freedom of Information Act and Privacy
      Operations concurrently with the filing of this response letter. Each
      instance in which privileged or confidential information has been omitted
      from this response letter has been identified herein by footnote. We have
      sent to you a paper copy of the Company's FOIA Confidential Treatment
      Request, including the privileged or confidential information to which it
      refers.

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Division of Corporation Finance
Attn: Mr. Don Walker
Page 2

                  -     staff comments or changes to disclosure in our filing
                        made in response to staff comments do not foreclose the
                        Commission from taking any action with respect to the
                        filing; and

                  -     the Company may not assert staff comments as a defense
                        in any proceeding initiated by the Commission or any
                        person under the federal securities laws of the United
                        States.

                                    COMMENTS

COMMENT 1  PLEASE TELL US WHAT EFFECT THE CHANGES IN ASSET QUALITY OF THE LOAN
           PORTFOLIO, SPECIFICALLY BUT NOT LIMITED TO THE INCREASE IN
           COMMERCIAL, FINANCIAL AND AGRICULTURAL LOANS, THE INCREASED
           CHARGE-OFFS, AND DECREASED RECOVERIES, HAVE HAD ON YOUR DETERMINATION
           OF THE ALLOWANCE ALLOCATION AND PROVISION FOR 2004.

           The increase in our nonaccruals from December 31, 2003 to December
           31, 2004 was primarily the result of two credits. One was to
           [____________](2) which had balances of $1,137,000 and $2,070,000 at
           December 31, 2003 and December 31, 2004, respectively. This credit
           was on nonaccrual at December 31, 2003 and management allocated
           $341,000 of the allowance at December 31, 2003 to this credit. This
           credit increased $933,000 from December 31, 2003 to December 31,
           2004, but due to the nature of the collateral securing this increase,
           management did not feel that an additional allowance allocation was
           warranted. Our reasons for making these additional advances are
           discussed in Comment 5. The second credit, which increased our
           nonaccruals, from December 31, 2003 to December 31, 2004, was a
           $1,500,000 loan to [____________](3). This loan was not on nonaccrual
           as of December 31, 2003. Management allocated $750,000 of the
           allowance at December 31, 2004 to this credit.

           While nonaccruals did increase $2,700,000 from 2003 to 2004, at the
           same time, our other classified loans decreased from $17,167,000 at
           December 31, 2003 to $12,438,000 at December 31, 2004. The allowance
           allocation related to our

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(2)   A complete response to this Comment would call for the disclosure of
      information that is covered by one or more exemptions in the Freedom of
      Information Act. In accordance with the Freedom of Information Act, we
      have omitted from this response letter trade secrets and commercial or
      financial information which are privileged or confidential. Such
      information is included in the Company's FOIA Confidential Treatment
      Request in the attachment identified with the following Identifying Number
      and Code: ENB-1.

(3)   A complete response to this Comment would call for the disclosure of
      information that is covered by one or more exemptions in the Freedom of
      Information Act. In accordance with the Freedom of Information Act, we
      have omitted from this response letter trade secrets and commercial or
      financial information which are privileged or confidential. Such
      information is included in the Company's FOIA Confidential Treatment
      Request in the attachment identified with the following Identifying Number
      and Code: ENB-2.

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Division of Corporation Finance
Attn: Mr. Don Walker
Page 3

           classified loans decreased $709,000 from 2003 to 2004, which
           essentially offset the $750,000 increase in the allowance allocated
           to [____________](4) discussed above.

           Total net charge-offs increased $1,555,000 from $158,000 during 2003
           to $1,713,000 during 2004 primarily due to one credit. Of the
           $1,713,000 of charge-offs during 2004, $1,545,000 related to this one
           credit for which management had allocated $834,000 of the allowance
           at December 31, 2003.

           In summary, management reviews the adequacy of the allowance for loan
           losses and the related provision on a quarterly basis taking into
           consideration nonaccrual loans, internally classified loans,
           charge-offs and the related allocations of the allowance to these
           credits. Management then makes a determination as to whether the
           allowance is sufficient to cover probable losses on these credits or
           whether the allowance needs to be increased by additional provisions
           to the allowance for loan losses. Management's determination was that
           the provision for 2004 was adequate to maintain the allowance for
           loan losses at a level sufficient to cover probable future losses in
           the loan portfolio at December 31, 2004.

COMMENT 2  PLEASE DESCRIBE FOR US ANY UNDERSTANDINGS OR AGREEMENTS YOU MAY HAVE
           WITH YOUR REGULATORS CONCERNING FUTURE CHANGES IN YOUR LEVELS OF LOAN
           LOSS PROVISION AND ALLOWANCE.

           Our Company and subsidiary banks have no understandings or agreements
           with any of our regulators concerning future changes in our levels of
           loan loss provision and allowance.

COMMENT 3  PLEASE PROVIDE US DETAILED INFORMATION ON THE LOANS COMPRISING THE
           $1.6 MILLION COMMERCIAL, FINANCIAL AND AGRICULTURAL LOANS CHARGED OFF
           FOR 2004, INCLUDING BUT NOT LIMITED TO THE SIZE, TYPE AND HISTORIC
           CIRCUMSTANCES SURROUNDING THE DECLINE IN THE ASSET QUALITY OF THE
           LOANS.

           $1,545,000 of the $1,596,000 of commercial, financial and
           agricultural loans charged off in 2004 represents borrowings of one
           customer. The customer is [____________](5). The loan to this
           customer has been internally classified as

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(4)   A complete response to this Comment would call for the disclosure of
      information that is covered by one or more exemptions in the Freedom of
      Information Act. In accordance with the Freedom of Information Act, we
      have omitted from this response letter trade secrets and commercial or
      financial information which are privileged or confidential. Such
      information is included in the Company's FOIA Confidential Treatment
      Request in the attachment identified with the following Identifying Number
      and Code: ENB-3.

(5)   A complete response to this Comment would call for the disclosure of
      information that is covered by one or more exemptions in the Freedom of
      Information Act. In accordance with the Freedom of Information Act, we

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Division of Corporation Finance
Attn: Mr. Don Walker
Page 4

           Substandard since the fourth quarter of 2002. During the first
           quarter of 2004, our Company placed the loan on nonaccrual when the
           liquidation value of our collateral did not appear to be sufficient
           to cover our principal and interest and the customer was experiencing
           cash flow problems. The customer was receiving what appeared to be
           profitable orders with prospects for more and they were in serious
           talks with several potential investors that, had their investments
           come to fruition, would have repaid our loans in their entirety.
           Although the loans were classified and on nonaccrual, we continued to
           make new advances to allow them to build product to fill incoming
           orders. During this period, the customer started a new division which
           looked as though it had promise and might, in conjunction with new
           sales orders, return the company to profitability. In the fourth
           quarter of 2004 one of the key principals of the new division died
           unexpectedly. With the death of this individual, the prospect of
           attracting venture capital was significantly diminished. As a result,
           we began to seriously question the customer's ability to turn the
           company around and continue as a going concern. We made the decision
           that we could no longer continue to provide financing to the customer
           and made demand on our notes. As a result, the customer went out of
           business and we began to liquidate and realize upon our collateral
           and we charged off $1,545,000 during the fourth quarter.

COMMENT 4  PLEASE TELL US HOW MUCH SPECIFIC LOAN LOSS ALLOWANCE HAD BEEN
           ESTABLISHED PRIOR TO 2004 FOR EACH OF THE LOANS COMPRISING THE $1.6
           MILLION OF COMMERCIAL, FINANCIAL AND AGRICULTURAL LOANS CHARGED OFF
           IN 2004.

           As of December 31, 2003 we had allocated $903,000 of our allowance
           for loan losses to the loans which were charged off in 2004.

COMMENT 5  PLEASE PROVIDE US WITH THE TYPE AND SIZE OF LOANS COMPRISING THE
           INCREASE OF $2.7 MILLION IN THE COMMERCIAL, FINANCIAL, AND
           AGRICULTURAL CLASSIFICATION OF THE NONACCRUAL LOANS TABLE FOR 2004.
           IDENTIFY HOW MUCH, IF ANY, SPECIFIC LOAN LOSS ALLOWANCE HAS BEEN
           RECORDED FOR EACH OF THESE LOANS.

           The $2.7 million increase in nonaccrual commercial, financial, and
           agricultural loans in 2004 was primarily represented by three
           credits. The first credit represents additional advances of $933,000
           to [____________](6), discussed in Comment 1 above, in order to
           assist the customer in returning the business to

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      have omitted from this response letter trade secrets and commercial or
      financial information which are privileged or confidential. Such
      information is included in the Company's FOIA Confidential Treatment
      Request in the attachment identified with the following Identifying Number
      and Code: ENB-4.

(6)   A complete response to this Comment would call for the disclosure of
      information that is covered by one or more exemptions in the Freedom of
      Information Act. In accordance with the Freedom of Information Act, we
      have omitted from this response letter trade secrets and commercial or
      financial information which are privileged or confidential. Such
      information is included in the Company's FOIA Confidential Treatment
      Request in the attachment identified with the following Identifying Number
      and Code: ENB-5.

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Division of Corporation Finance
Attn: Mr. Don Walker
Page 5

           profitability. This customer had nonaccrual loan balances of
           $2,070,000 at December 31, 2004 compared to $1,137,000 at December
           31, 2003. $310,500 of the allowance was allocated to this credit at
           December 31, 2004.

           The second credit of $364,000 represents the residual debt of
           [____________](7) discussed in Comment 3 above. We anticipate this
           credit, net of the allocated allowance of $55,000, will be paid off
           from the proceeds received from the liquidation of collateral.

           The third credit of $1,500,000, discussed in Comment 1 above,
           represents a loan to [____________](8). We are currently holding $1.2
           million of cash collateral; however, we are currently defending our
           collateral position in Chapter 11 bankruptcy court. $750,000 of the
           allowance was allocated to this credit at December 31, 2004.

            We hope that the above has been of assistance to you and that it is
fully responsive to your comments. If you have any questions or require any
further information, please call me at (660) 885-2241.

                                         Very truly yours,

                                         James E. Smith
                                         Chairman and CEO

cc: Ms. Paula Smith

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(7)   A complete response to this Comment would call for the disclosure of
      information that is covered by one or more exemptions in the Freedom of
      Information Act. In accordance with the Freedom of Information Act, we
      have omitted from this response letter trade secrets and commercial or
      financial information which are privileged or confidential. Such
      information is included in the Company's FOIA Confidential Treatment
      Request in the attachment identified with the following Identifying Number
      and Code: ENB-6.

(8)   A complete response to this Comment would call for the disclosure of
      information that is covered by one or more exemptions in the Freedom of
      Information Act. In accordance with the Freedom of Information Act, we
      have omitted from this response letter trade secrets and commercial or
      financial information which are privileged or confidential. Such
      information is included in the Company's FOIA Confidential Treatment
      Request in the attachment identified with the following Identifying Number
      and Code: ENB-7.
<PAGE>

                                                              September 16, 2005

Division of Corporation Finance
Securities and Exchange Commission
Mail Stop 4561
450 Fifth Street, N.W.
Washington, DC 20549

Attn:    Mr. Don Walker
         Senior Assistant Chief Accountant

                                        Re: Exchange National Bancshares, Inc.
                                            Form 10-K for the year
                                            ended December 31, 2004
                                            SEC File No. 000-23636

Dear Mr. Walker:

             We are writing in response to your letter dated September 2,
2005, with respect to the above referenced report filed by Exchange National