SecProbe.io

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                           COMMUNITY BANKSHARES, INC.
                              791 Broughton Street
                        Orangeburg, South Carolina 29115

                                October 11, 2005
Via EDGAR

Mr. John P. Nolan
Accounting Branch Chief
Office of Financial Services
Division of Corporation Financial Services
U. S. Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549

         Re:      Community Bankshares, Inc.
                  Form 10-K filed March 31, 2005
                  File No. 001-12341

Dear Mr. Nolan:

         This letter  responds to your letter dated  September 7, 2005 addressed
to me containing comments on Forms 10-K and 10-Q for the year ended December 31,
2004 and the first and second  quarters of 2005 filed by  Community  Bankshares,
Inc. (the "Company").  For your convenience,  we have repeated your comments and
our  responses  follow each  comment.  Bullet  points in the comments  have been
replaced  with numbers to aid in  referencing  each  comment.  Your comments are
preceded by "COMMENT" and our responses are preceded by "RESPONSE."

Form 10-K for the Year ended December 31, 2004

COMMENT

MD&A, "Provision for Loan Losses", page 19

1.   We note the  $3.983  million or 356%  increase  in the  provision  for loan
     losses in 2004 as compared  to 2003,  was  associated  with  several  large
     problem  commercial  loans,  most of which were handled by a former lending
     officer.  In  this  regard,  please  tell  us  and  include  the  following
     information in future filings:

     1.1. Quantify  the  portion  of the  provision  for  loan  losses  for 2004
          attributable  to the problem  commercial  loans  handled by the former
          lending  officer and describe how the related portion of the provision
          was determined.

                                       1
<PAGE>

RESPONSE

The total amount  charged to provision  associated  with the former loan officer
was $3,241,000.  About  $1,433,000 of the provision  expense was associated with
three loans secured  directly or indirectly by the declining  value of the stock
in a small publicly traded company.  About  $1,742,000 of the provision  expense
was associated with two commercial customers involving  bankruptcies.  The value
of the underlying  collateral  was  determined to be  negligible.  The remaining
provision  expense of $66,000 was associated  with a loan where the customer had
severe cash flow  problems.  A specific  allocation of the loan loss reserve was
made based on the estimated net realizable value of the collateral.

The  provision  expense for each loan was  determined  by taking the charged off
amount plus the end of period  specific  allocation less any beginning of period
allocation.

COMMENT

     1.2. Describe  the  original  repayment  and other  terms of the loans that
          became   nonperforming,   including  the  nature  of  any   underlying
          collateral and how its fair value was determined.

RESPONSE

The  $4,043,000  in  loans  that  became   nonperforming  were  single  payment,
short-term,  loans, with principal and interest due at maturity. Of these loans,
approximately  $1,850,000  was  directly or  indirectly  secured with stock of a
small,  publicly  traded  company.  At the inception of these loans the reported
trading value of each share was  approximately  $5; by the time of  management's
review, the reported trading value had become negligible.

Of these loans,  approximately  $1,000,000 was secured with the  receivables and
inventory of a small  business.  This customer  declared  bankruptcy  during the
fourth quarter and it was determined that the actual value of the collateral was
a very small fraction of the amount of the loan.

Of these  loans,  approximately  $750,000  was secured  with the  equipment  and
fixtures of a bankrupt business. The bank found issues with the valuation of the
underlying collateral and the bank's perfection of its security interest.

The  remaining   loan  balance,   approximately   $443,000,   was  secured  with
construction  contract receivables and retainages where management estimated net
realizable value of the collateral.

COMMENT

     1.3. State the portion of the net  charge-offs  for $4.961  million in 2004
          that were attributable to these loans and how the amount and timing of
          the charge off was determined.

                                       2
<PAGE>

RESPONSE

Of the net charge-offs of $4,961,000 in 2004,  $2,950,000  were  attributable to
the problem commercial loans of the former lending officer.  For the loans where
the  underlying  collateral  was  stock,  management  assessed  the value of the
collateral based on current market  conditions and an assessment of the issuer's
financial  condition.  Loan  chargeoffs  of  $1,200,000  were made based on that
information  and the  customers'  failure to perform upon demand.  For the loans
associated  with  customer  bankruptcies,  management  assessed the value of the
collateral as soon as it became aware of customer's financial  circumstances and
charged the loans down appropriately,  for a total chargeoff of $1,750,000.  For
the remaining loan, management made a specific provision, not a chargeoff, based
on a qualitative assessment of information available in the credit file.

COMMENT

     1.4. Describe the specific  events which occurred in 2004 that caused these
          loans to be classified as non performing and subsequently written off.

RESPONSE

Late in the second quarter of 2004 the Company's senior  management became aware
of certain  loans  that  might be  potential  problem  loans,  all of which were
associated  with one senior  loan  officer.  Management  directed  the  internal
auditors to review all of those loans.

At the time of the filing of the Company's  Form 10-Q for the second  quarter of
2004,  all but  one of the  identified  loans  was  performing  as  agreed.  The
potential problem loan, in the amount of $824,000, was disclosed in the June 30,
2004 10-Q. Using currently available  information  management determined that no
additional  provision for loan losses with respect to the  identified  loans was
required as of the quarter ended June 30, 2004.

In the third quarter of 2004, two borrowers, unrelated to the loans in the above
mentioned   review,   with  loans  totaling   $1,750,000   were  found  to  have
significantly   deteriorated   financial   conditions.   The  prospects  of  any
significant recovery from the loans' collateral were believed to be unlikely. As
of the end of the 2004 third quarter,  $1,375,000 was specifically  allocated in
the  allowance  for loan  losses  for  these  loans.  Also,  at the  same  time,
$2,547,000 of the single  payment  loans,  identified in the internal  auditors'
review (see response to comment 1.2), were classified as potential problem loans
because of  performance  concerns.  This was disclosed in the 2004 third quarter
Form 10-Q.

During  the fourth  quarter  of 2004,  the two loans  totaling  $1,750,000  were
charged off, and $1,850,000 of the aforementioned $2,547,000 of loans was placed
in  nonaccrual  status with  $1,200,000  charged  off by year end as  additional
information  became  available to  management.  The  $1,750,000  in  charge-offs
resulted  from the bank's  being  advised of the  bankruptcy  declarations.  The
$1,200,000 in  charge-offs  resulted from the bank's  ongoing  assessment of the
value of the underlying collateral and the customers' unwillingness or inability
to perform upon demand of the bank. Of the $697,000 remainder  ($2,547,000 minus
$1,850,000 placed in nonaccrual),  $497,000 was collected during the 2004 fourth
quarter and $200,000 was performing  but remained in potential  problem loans at
December 31, 2004.

                                       3
<PAGE>

COMMENT

     1.5. Describe any related party or other relationships  between the lending
          officer and other  Company  officials  and the  borrowers who obtained
          these loans.

RESPONSE

After  reviewing  the  definitions  included  in  Regulation  S-K,  Article 9 of
Regulation S-X, or Statement of Financial Accounting Standards No. 57, we do not
believe there were any related party relationships  between the lending officer,
other  Company  officials  and the  borrowers who obtained the loans that became
nonperforming.

COMMENT

     1.6. Provide the analysis performed by management with respect to these and
          similar loans that led them to believe the underlying causes for these
          problems were isolated and not indicative of a trend.

RESPONSE

Management  became aware of the potential  problem loans in late second  quarter
2004.  Because of the dollar  magnitude of the loans,  management  was concerned
that a trend in the  portfolio  could be  becoming  evident.  In order to better
understand  the potential  problems loans it ordered an internal audit review of
the loans.

As of December 31, 2004,  management believed that the underlying causes for the
problems  associated  with the former  lending  officer's  loan  portfolio  were
isolated and not  indicative of a trend.  The rationale for this belief was that
most of the loans  identified in the internal audit review centered on borrowers
whose  collateral  was  directly  or  indirectly  tied to the  stock of a small,
publicly traded, but financially  troubled company located outside of our normal
market area.  Each of the loans  identified  in the  internal  audit review were
individually evaluated for potential loss. The majority of these loans performed
as agreed or have paid out.  Those loans deemed to have the highest  credit risk
have been dealt with in due course  with loan loss  provisions  and  charge-offs
accounted for in the proper  quarters based on  management's  assessments  using
current information as of each period end.

Three other loans in this former loan officer's  portfolio  totaling  $2,193,000
moved into  nonperforming loan status in the last half of 2004. These loans were
not included in the list of loans for which the  internal  audit review had been
directed.  Analysis  during  the third and  fourth  quarters  of 2004  indicated
specific  unrelated  business problems of the borrowers that resulted in adverse
classification.  In the 2004 third  quarter,  $1,750,000 of the  $2,193,000  was
placed into nonaccrual.  One loan for $443,000 moved into nonaccrual in the 2004
fourth quarter.  The two loans totaling  $1,750,000 involved a bankrupt business
and a borrower  who had  depleted  his  personal  assets in a bankrupt  business
venture.  The $443,000 loan  involved a customer with severe  business cash flow
problems.

                                       4
<PAGE>

As of December 31, 2004,  the Company's  management  analyzed the loan portfolio
using the internal risk grading system and loan review reports. Neither of these
resources  signaled a trend,  nor did the internal  audit  report.  The problems
loans that were found centered on weak collateral and isolated  financial issues
of a very small number of customers.  Also,  because the former lending  officer
had been gone for six months and it was believed that the  significant  problems
with his portfolio had been dealt with appropriately,  management concluded that
its concerns about a trend in the portfolio were not borne out.

COMMENT

2.   Please  tell us and in future  filings  provide the  following  information
     regarding  the  write-down  on a large  commercial  loan that  financed the
     purchase of a business:

     2.1. State the terms and principal  amount of the commercial  loan that the
          borrower used to purchase the business,  including the nature and fair
          value  of any  underlying  collateral  and  how  its  fair  value  was
          determined.  Provide a cross  reference to the specific  nonperforming
          loan for $2.4  million  which is  discussed  in the  "Impaired  Loans"
          section on page 23.

RESPONSE

The original principal amounts of the loans made to facilitate the purchase of a
business totaled $3,500,000, comprising two variable rate notes, each dated July
2, 2004. The original terms of the notes required  monthly payments of principal
and  interest  beginning  August 1, 2004  based on an  initial  240 month  term.
Repayment  amounts  were to be  adjusted  annually  at each  of the  first  four
anniversaries  in conjunction  with scheduled  changes in the variable  interest
rate. The remaining  balance was to be paid in a balloon  payment due on June 1,
2009.  The notes  were  collateralized  by real  estate,  equipment,  and rights
related to certain  restaurant  franchise  agreements.  Appraised values totaled
$4,100,000 as determined by an independent appraiser.

Through December 31, 2004, the principal amounts of these loans had been reduced
to $3,435,000 as a result of the receipt of the scheduled monthly payments.  The
balance as of December  31, 2004 was written  down to  $2,434,000.  This was the
result of an  internal  evaluation  of the value of the  underlying  collateral,
which  determined that a one million dollar partial  charge-off was appropriate.
This evaluation was based on the business' not being a going concern; in effect,
a worst case estimate.  This  determination  was  substantiated  by a subsequent
independent  appraisal conducted in April 2005, which established a new value at
approximately  $2,700,000.  Management's  intention  at December 31, 2004 was to
write-down the carrying amount of the loan to the estimated net realizable value
of  the  underlying   collateral   and,  in  management's   opinion,   this  was
accomplished. The borrower was at that time acting to sell the business.

Also see also the response to comment 5.

                                       5
<PAGE>

COMMENT

     2.2. Discuss the nature and extent of the legal  options  which the Company
          is  pursuing  to  receive  payment  for  these  non  performing  loans
          considering  the  business  purchased  by the  borrower  is accused of
          committing fraud.

RESPONSE

The Company has engaged an attorney to assist with  respect to these  loans.  On
March 22, 2005 the Company and  borrower  signed a note  modification  agreement
which  suspended the required  payments of principal and interest for the period
from  January 1 through  June 30, 2005 and the  borrower  assigned any rights or
proceeds  resulting from any litigation the borrower might initiate  against the
former  business  owner.  The Company is pursuing this  forbearance  strategy in
order  to  increase  the  likelihood  that the  business  can be sold as a going
concern,  which management  believes would help maximize its potential recovery.
The Company is  currently  in the  process of  negotiating  with the  borrower a
renewal of the forbearance agreement.

COMMENT

Noninterest income, page 19.

3.   We refer to the "Noninterest income" section of MD&A on page 19 that states
     the Company  initiated in 2004 measures  intended to decrease the costs and
     complexity of funding your mortgage brokerage operation. Please tell us and
     in future filings discuss in MD&A the specific measures that were initiated
     to reduce these costs and  quantify  the effects on  operating  income that
     have resulted from implementing this cost reduction plan.

RESPONSE

The company acquired its mortgage company,  Community Resource  Mortgage,  Inc.,
(hereafter  CRM) in late 2001.  During 2002 and 2003 CRM's loan  production  was
funded with a warehouse line provided by a nonaffiliated  financial institution.
During  most of this  period,  demand  for  mortgage  loans was high and did not
decrease until late 2003. During earl