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Correspondence

 August 25, 2011

 Christian Windsor, Esquire

 Special Counsel

United States Securities and Exchange Commission

100 F Street, NE

 Washington, DC 20549

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. Windsor:

 This responds to your letter dated August 3, 2011
relating to the above referenced Form 10-K, 10-K/A, and 10-Q filings. For your convenience, the text of the comments are provided below, followed by our response.

 This letter is being filed with the Securities and Exchange Commission (“Commission” or “SEC”) on EDGAR supplementally as correspondence, and a complete copy of this letter in paper
format is also being forwarded to you by overnight delivery. Please note that this letter omits confidential information included in the unredacted version of the letter that was delivered to the Division of Corporation Finance and that asterisks,
as indicated below, denote such omissions.

 We respectfully request, pursuant to the provisions of 17 C.F.R. § 200.83
(“Rule 83”), that confidential treatment under the Freedom of Information Act (“FOIA”) (5 U.S.C. § 552) be afforded to certain portions of our responses (the “Confidential Materials”). The Confidential Materials
are marked with bracketed asterisks [***], and the pages on which they appear is marked with the confidentiality legends as required by Rule 83. We believe that the Confidential Materials contain information that is covered by one or more exemptions
in the FOIA, for reasons of business confidentiality. If any person who is not an employee of the Commission, including any other government employee, requests an opportunity to inspect or copy the materials referred to in this letter, pursuant to
the FOIA or otherwise, we request in accordance with Rule 83 that the Company be promptly notified of any such request and furnished with a copy of all written materials pertaining to such request, so that we may further substantiate the foregoing
request for confidential treatment. Please address any notification of a request for access to such documents to the undersigned with a copy to Douglas W. Densmore at (540) 510-3024 (facsimile: (540) 510-3050) or Hugh B. Wellons at
(540) 510-3057 (facsimile: (540) 510-3050). The telephone and facsimile numbers for Mr. Asbury are [***] and (276) 873-7003 (fax), and for Mr. Mullins are [***] and (276) 873-7505 (fax).

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

1.
 In the initial version of your 10-K, filed March 16, 2011, you indicated that you intended to file a proxy statement for your annual meeting,
which would include your Part III Page 2 information. In the April 29 amendment to the 10-K you included the Part III information, and have not

 Mr. Christian Windsor

 United States Securities and Exchange Commission

 August 25, 2011

 Page
 2

subsequently filed 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.

 Response: We
established the date of our annual meeting at our most recent Board of Directors meeting as November 7, 2011, with a shareholder record date of September 20, 2011. Subsequent to the shareholder record date, we will file the proxy statement
for that annual meeting. The normal time period that we hold our annual meeting is mid-May. However, [***] we decided to postpone the annual meeting [***]. Unfortunately [***], we discovered that a restatement of our financial statements for
December 31, 2010 was necessary. These circumstances required us to include the Part III information in our 10-K amendment. Once we completed the restatement, the SEC initiated a review of our filings. We did not feel comfortable establishing a
shareholder record date and annual meeting date until the end of the SEC comment period and satisfactory resolution of the issues. However, after discussing this with SEC Staff, we were encouraged to set that date. The annual meeting date, although
considerably later than usual, does not violate Virginia law. We are not currently listed on a national exchange and, therefore, not subject to listing standards.

 Our Market Areas, page 5

2.
We note your dependence on your local market area, described in the related risk factor on page 21. In future filings, please revise to provide economic figures
reflecting current conditions in your market area, as well as significant 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.

 Response: We will provide the requested information in our Form 10-K filing for
December 31, 2011.

 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 referenced an evaluation that is made to
determine if the collateral is sufficient for these credits. Please tell us and revise your future filings beginning with your next Form 10-Q to disclose your appraisal policies and procedures. In your revised disclosures, please include the
following:

•

 explain when you consider an appraisal to be outdated and whether this varies by loan type;

•

 discuss in further detail the evaluation that is performed 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 result of outdated appraisals;

•

 discuss how you consider the potential for outdated appraisal values in your determination of the allowance for loan losses; and

•

 quantify the amount of collateral dependent loans for which you are using an appraisal performed within the past 12 months to serve as the primary
basis of your valuation.

 Mr. Christian Windsor

 United States Securities and Exchange Commission

 August 25, 2011

 Page
 3

 Response:

•

 explain when you consider an appraisal to be outdated and whether this varies by loan type;

We consider an appraisal to be outdated when the appraisal is greater than 12 months old and an individual credit exhibits signs of
weakness that warrants the possibility of relying upon the collateral for potential repayment.

•

 discuss in further detail the evaluation that is performed on the underlying collateral to determine whether it is sufficient;

 An independent appraisal department reviews the appraisal to ensure compliance with USPAP requirements. The
appraisal is further reviewed by the loan officer and Chief Credit Officer for reasonableness. If the appraised value is questionable, an independent third party review of the appraisal is obtained.

•

 how often you obtain updated appraisals for your impaired collateral dependent loans and if this policy varies by loan type;

 We obtain appraisals on adversely classified loans annually for all loan types. This is a new policy
adopted in mid 2010. Prior to this date, the period was 18 months. We have given higher priority to construction and development, as well as commercial real estate type loans in the past year as these have been more sensitive to market
deterioration. With the recent development of a Special Assets division, concentrated efforts on these problem credits are underway and current appraisals are being obtained in order of priority. We anticipate all of these loans to have a current
appraisal obtained by the end of 2011.

•

 describe in more detail the types of adjustments you make to appraised values, including those made as a result of outdated appraisals;

 If appraisals are obtained “as is”, we further discount these appraisals with an estimated
selling cost of 10% for commercial and development type properties, and 6% for residential mortgages. If a current appraisal has not been obtained, we discount the most recent appraised value by age, ie. Greater than one year through two years is
discounted 10%, two years to three years discount is 20%, and greater than 3 years are discounted 30%. For distressed out of market loans, we compare the credit to a similar current dated appraisal and discount accordingly until a current appraisal
is obtained.

•

 discuss how you consider the potential for outdated appraisal values in your determination of the allowance for loan losses; and

 In determination of the FAS 5 component of our allowance for loan losses, we do not directly consider the
potential for outdated appraisals, since that portion of our allowance is based on the analysis of the performance of loans with similar risk characteristics, external risk factors and internal risk factors. We do consider the overall quality
of our underwriting processes in our internal risk factors; but the need to update appraisals is associated with loans identified as impaired under FAS 114.

 In determination of the FAS 114 component of our allowance for loan losses, for loans determined to be impaired under the standard, we specifically confirm the current status of appraisals as outlined in
the items noted above.

•

 quantify the amount of collateral dependent loans for which you are using an appraisal performed within the past 12 months to serve as the primary
basis of your valuation.

 Mr. Christian Windsor

 United States Securities and Exchange Commission

 August 25, 2011

 Page
 4

 $42.4 million in collateral dependent loans have current appraisals and this is the
basis of the valuation less estimated selling costs.

 We will revise our future filings, beginning with
the 3rd quarter 2011 Form 10-Q, to include the revised
disclosures discussed above.

4.
As a related matter, we also note that as a result of the material weakness identified in your internal control over financial reporting as of December 31, 2011
you state on page 79 that the Chief Credit Officer is now responsible for determining when appraisals or evaluations will be needed on impaired loans and 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.

Response: As noted above, by policy we consider an appraisal to be outdated when the appraisal is greater than 12 months old and an
individual credit exhibits signs of weakness that warrants the possibility of relying upon the collateral for potential repayment. However, the Chief Credit Officer has discretion in determining which appraisals must be updated, in what order, and
which may be deferred. The Chief Credit Officer evaluates the type of project associated with the credit, the age of the related appraisal and his market knowledge with respect to that type collateral in making his determination.

For example, acquisition, development and construction (ADC) credit appraisals will be updated earlier and more frequently than for owner
occupied real estate which are in similar payment status. The basis for this discretion and treatment is that we have determined that the former project types are subject to more market price volatility than the latter types.

For additional clarification, we offer the following.

 Our policy is to obtain appraisals on adversely classified loans as required for all loan types, which is a new policy adopted in mid-2010. However, we have given higher priority to construction and
development (ADC), as well as commercial real estate type loans in the past year as these have been more sensitive to market deterioration.

 Generally, the lack of cash flow to service the related debt results in a downgrade. At the time of the downgrade and pursuant to FAS 114, we determine potential loss exposure. The type of collateral
plays a role in determining whether a new appraisal is ordered. The age and type of the existing appraisal are also keys in the decision. For example, purpose of the loan is land development and we have a 2009 appraisal, we would order a new
appraisal, consistent with exhibited market deterioration. Also by example, if a loan is secured by a warehouse with a single tenant and no changes in the lease or payment history, we may rely on the 2009 appraisal.

A final factor in the decision is whether the original appraisal was certified or performed in house. Given our prior experience of
inaccuracies in a higher percentage of in house valuations, a new certified appraisal would generally be ordered. With the recent development of our Special Assets division, concentrated efforts on these problem credits are underway and current
appraisals are being obtained in order of priority. We anticipate all of these loans to have a current appraisal obtained by the end of 2011 if they are individually or collectively material.

 Mr. Christian Windsor

 United States Securities and Exchange Commission

 August 25, 2011

 Page
 5

 All properties that are carried in ORE are appraised at foreclosure, and booked at that
value, less 10% sales costs. The ORE properties are re-appraised every 12 months per policy, with carrying values adjusted appropriately.

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 dependent 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 appraisal obtained for the underlying 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 appraisal subsequent to either June 30, 2011 and December 31, 2010 and how you considered these 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.

 Response: Four of the five loans for each
period are for commercial or residential real estate development. Three of five loans in each period are out of our principal market area. For more details relating to this, please see Attachment 1.

Note 7. Loans, as Restated, page 58

6.
We note in your Banking Services section beginning on page 6 you discuss your current loan offerings. Please tell us how you considered 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 financing receivable for purposes of providing the disclosures required by ASU 2010-20 based upon the following:

•

 Commercial real estate loans 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 residential loan portfolio segment;

 Based upon the different credit risk characteristics related to the different loans included in your current
loan portfolio segments, please consider revising your future filings to separately disclose the above mentioned loans as a separate class of financi