SecProbe.io

August 3, 2011
  Via E-mail

C. Todd Asbury Chief Financial Officer New Peoples Bankshares, Inc. 67 Commerce Drive Honaker, Virginia  24260
Re: New Peoples Bankshares, Inc.
Form 10-K for the fiscal year ended December 31, 2010 Filed March 16, 2011 10-K/A’s for the fiscal year ended December 31, 2010 Filed April 29 and June 24, 2011 Form 10-Q for the Quarter ended March 31, 2011 Filed June 28, 2011 File No. 0-33411

Dear Mr. Asbury:
 We have reviewed your filing and have the following comments.  In some of our
comments, we may ask you to provide us with  information so we may better understand your
disclosure.
 Please respond to this letter within ten business days by amending your filing, by
providing the requested information, or by advi sing us when you will provide the requested
response.  Where we have requested changes in  future filings, please include a draft of your
proposed disclosures that clearly identifies new or revised disclosu res.  If you do not believe our
comments apply to your facts and circumstances or  do not believe an amendment is appropriate,
please tell us why in your response.
 After reviewing any amendment to your filing and the information you provide in
response to these comments, including the draf t of your proposed disclosures, we may have
additional comments.

 Form 10-K/A #2 for Fiscal Year Ended December 31, 2010

 General

1. In the initial version of your 10-K, file d March 16, 2011, you indicated that you intended
to file a proxy statement for your annual meeting, which would in clude your Part III

Mr. C. Todd Asbury New Peoples Bankshares, Inc. August 3, 2011 Page 2
 information.  In the April 29 amendment to the 10-K you included the Part III
information, and have not subsequently file d a proxy statement for your annual meeting.
Please tell us regarding your plans to conduct an annual meeting this year, and provide
your analysis of the impact of a decision not to conduct a meeting this year under your
applicable listing standards and Virginia law.
 Our Market Areas, page 5

2. We note your dependence on your local market ar ea, described in the related risk factor
on page 21.  In future filings, please revise to provide econo mic figures reflecting current
conditions in your market area, as well as si gnificant changes and trends over the past
several years.  These might relate to average income, housing starts and sales,
foreclosures and commercial business figures such as total employment or the like.
 Provision for Loan Losses, page 33

3. We note your disclosure on page 34 that if collateral appraisals are outdated you will
obtain updated appraisals, and you have refere nced an evaluation that is made to
determine if the collateral is sufficient for these credits.  Please te ll us and revise your
future filings beginning with your next Form 10-Q to disclose your appraisal policies and
procedures. In your revised disclosu res, please include the following:

 explain when you consider an appraisal to be outdated and whet her this varies by
loan type;
 discuss in further detail the evaluation that is performe d on the underlying collateral
to determine whether it is sufficient;
 how often you obtain updated appraisals for your impaired collateral dependent
loans and if this policy varies by loan type;
 describe in more detail the types of adjustments you make to appraised values,
including those made as a re sult of outdated appraisals;
 discuss how you consider the potential fo r outdated appraisal values in your
determination of the allowance for loan losses; and
 quantify the amount of collateral depende nt loans for which you are using an
appraisal performed within th e past 12 months to serve as  the primary basis of your
valuation.
4. As a related matter, we also note that as a result of the material weakness identified in
your internal control over financial reporti ng as of December 31, 2011 you state on page
79 that the Chief Credit Officer is now res ponsible for determining when appraisals or
evaluations will be needed on impaired loans an d other real estate owned properties.  To
the extent not already provided, please tell us in further detail how the Chief Credit
Officer determines when appraisals and evaluations will be performed.

Mr. C. Todd Asbury New Peoples Bankshares, Inc. August 3, 2011 Page 3
 5. To further enhance our understanding of  how you measure impairment under ASC 310-
30, please provide us with details of your five  largest collateral depe ndent impaired loans
at June 30, 2011 and December 31, 2010.  Your response should include a discussion of
the following:

 when the loan was originated;
 when the loan became impaired;
 the underlying collateral supporting the loan;
 the amount of any charge-offs recognized for the loan, as applicable;
 the date and amount of the last appraisa l obtained for the unde rlying collateral;
 the estimated fair value of the underlying collateral at June 30, 2011 and December
31, 2010;
 if you applied a discount to the most recent appraised value, the discount applied and
how it was determined;
 whether you have received an appraisa l subsequent to either June 30, 2011 and
December 31, 2010 and how you considered th ese updated appraised values as of
previous period end; and
 any other pertinent information deemed necessary to understand your review of the
loan and related accounting subsequent to  the receipt of your last appraisal and
through the date of your response.

Note 7. Loans, as Restated, page 58

6. We note in your Banking Serv ices section beginning on pa ge 6 you discuss your current
loan offerings.  Please tell us how you cons idered the guidance in paragraphs ASC 310-
10-55-16 through 18 in determining whether your current loan portfolio segments should
be  classified as a separate class of fina ncing receivable for pu rposes of providing the
disclosures required by ASU 2010- 20 based upon the following:

 Commercial real estate loan s are currently included within your commercial loan
portfolio segment;
 Residential first and second loans and home  equity lines of credit  are currently
included within your residentia l loan portfolio segment;
 Based upon the different credit risk characterist ics related to the diffe rent loans included
in your current loan portfolio segments, plea se consider revising your future filings to
separately disclose the above mentioned loans as  a separate class of financing receivable.
If you do not believe disclosing these loan portf olios as  separate classes is necessary
please provide us with credit quality informa tion (specific allowance, charge-off’s, etc.)
which supports your determination that thes e portfolios do not re present a significant
credit risk.
 7. Please revise your Age Analysis of Past Due Loans Receivable tabular disclosure on page
59  in future filings to further breakout th e amounts included in the 30-89 days past due

Mr. C. Todd Asbury New Peoples Bankshares, Inc. August 3, 2011 Page 4
 bucket into loans past due 30-59 days and loans past due 60-89 days.  Refer to ASC 310-
10-55-9 for guidance.

8. We note your disclosure on page 59 that inte rest income recognized on impaired loans for
December 31, 2010 was $4.0 million. Please revise future filings to disclose your policy
for recognizing interest income on impaired lo ans and to disclose how cash receipts are
recorded.  Refer to ASC 310-10-50-15(b).
  Form 10-Q for Fiscal Quarter Ended March 31, 2011

 Note 3. Formal Written Agreement, page 6

9. We note your disclosure of the formal writte n agreement with the Federal Reserve Bank
of Richmond and the Virginia State Cor poration Commission Bu reau of Financial
Institutions which was entered into on Ju ly 29, 2010. We also note your statement that
under the terms of this agreement you have ag reed to strengthen credit risk management
policies, enhance lending and credit admi nistration, enhance management of your
commercial real estate concentrations, conduc t ongoing review and grading of your loan
portfolio, and review and re vise, as appropriate, current  policy and maintain sound
processes for maintaining an adequate allowanc e for loan and lease losses.  To the extent
that such initiatives are expected to have a material impact on your results of operations,
financial position, or liquidity, please revise you r future filings to disclose in detail the
changes you have made or intend to make  to comply with this guidance.

10. Tell us about, and revise your disclosure in fu ture filings to describe , all material actions
taken or to be taken by Peoples Bancorporati on, or its subsidiary banks, to address the
requirements of any agreements with your re gulators.  For confid ential or informal
agreements, do not disclose the terms of thos e agreements; instead discuss the actions and
affects of the actions taken or to be taken.  With regard to the formal agreements, provide
updated disclosure regarding any changes or additional actions take n in the relevant
periods and disclose management’s conclusi on as to whether you are in compliance with
the terms of th e agreement.

Note 7. Allowance for Loan Losses, page 11

11. We note from your tabular disclosures on page s 11-12 that your unallocated allowance
for loan losses totaled $6.377 million and $6.163 million as of March 31, 2011 and December 31, 2010, respectively, which represents 33% and 25% of your total allowance for loan losses as of these periods. We al so note disclosure on page 34 of your most
recent Form 10-K/A for December 31, 2010 that  as a result of a change in methodology
in the last quarter of 2009 your unallocated al lowance represents your  internal processes
of underwriting and the inherent  risks present in your loan portfolio due to past and
present lending practic es.  Based upon the significant amount of unallocated allowance

Mr. C. Todd Asbury New Peoples Bankshares, Inc. August 3, 2011 Page 5
 for loan losses as of these period ends, please tell us and consider revising future filings
to present additional granularity by enhancing your current disclosures regarding the amount of the unallocated allowance assigned to each class or por tfolio segment and
discuss any trends or changes from prior periods related to this amount.
   We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requir e.  Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.                In responding to our comments, please provide a written statement from the company
acknowledging that:
 the company is responsible for the adequacy an d accuracy of the disclo sure in the filing;

 staff comments or changes to disclosure 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 federa l securities laws of  the United States.
  You may contact John Spitz, staff accountan t, at 202-551-3484 or John Nolan, Senior
Assistant Chief Accountant, at 202-551-3492 if you have ques tions regarding comments
regarding the financial statemen ts and related matters.  Please  contact David Lyon at 202-551-
3421 or me at 202-551-3419 with any other questions.
Sincerely,
    /s/ Christian Windsor
Christian Windsor Special Counsel
Cc:
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 Douglas Densmore
    LeClair Ryan