SecProbe.io

October 26, 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 Form 10-Q for the quarter ended June 30, 2011 Filed August 8, 2011  File No. 0-33411

Dear Mr. Asbury:
 We have reviewed your response letter dated August 25, 2011, and your most recent
Form 10-Q, 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

 Provision for Loan Losses, page 33

 1. We note your response to comment five from our  letter dated August 3, 2011. As it relates to
loan four in Attachment 1 as of June 30, 2011, please address the following:

Mr. C. Todd Asbury New Peoples Bankshares, Inc. October 26, 2011 Page 2
  Explain further how this appraisal was consider ed in your allowance for loan losses as of
June 30, 2011; and
 It appears that this loan was deemed to be impaired on December 31, 2009 but did not
receive an updated appraisa l until July 15, 2011. Please tell us how you determined the
specific reserve and amounts to charge-off prior to the receipt of th is updated appraisal
taken into consideration that th is is a loan participation.

2. As a related matter, please provi de us a detail of collateral de pendent impaired loans as of
June 30, 2011 for which you received an appraisa l subsequent to quarter end, but for which
you did not include the appraisa l into your allowance for loan  losses similar to what may
have occurred the loan specifically identified in our previous comment. For each of these
loans, please explain to us furthe r the reasons these appraisals we re not considered as of June
30, 2011, as applicable.
 3. Please also provide us with a detailed unde rstanding of your policies and procedures
implemented to ensure that you appropriately acc ount for appraisals rece ived subsequent to
period end but prior to the issuance of your fi nancial statements pursuant to ASC 855. Noting
that this issue resulted in th e restatement of your Form 10-K fo r fiscal year ended December
31, 2010 we believe that enhanced disclosure in your future filings is necessary.
 4. We note your response to comment five from our  letter dated August 3, 2011. As it relates to
one of your loans as of December 31, 2010 include d in Attachment 1 (loan three), please tell
us in detail how you determined the amounts to charge-off and record as a specific reserve
taken into consideration that the most rece nt appraisal value resulted in a valuation
significantly in excess of the net carrying value.
 5. We note your response to comment seven fr om our letter dated August 3, 2011. Based upon
the classes of financing receivables for your loan portfolio as provided in your response,
please confirm to us that you will include all of  the disclosure requirements required by ASU
2010-20 in your Form 10-Q for the period ende d September 30, 2011. Please also provide us
with these revised disclosures as of September 30, 2011 if available or as of June 30, 2011.
 Form 10-Q for Fiscal Quarter Ended March 31, 2011

 6. In your response to our prior comments 9 and 10  you seem to limit future disclosure about
the agreements to changes subsequent to the situation described in your letter of August 25,
2011.  In your Form 10-Q for the quarter ende d September 30, 2011, please confirm that you
will disclose the material, baseline information consistent with your responses to comments 9 and 10.
   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

Mr. C. Todd Asbury New Peoples Bankshares, Inc. October 26, 2011 Page 3
 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: Via E-mail

 Douglas Densmore  LeClair Ryan