Correspondence 0001903596-24-000615 from NEW PEOPLES BANKSHARES INC (NWPP)
NEW PEOPLES BANKSHARES INC
Date: Oct. 11, 2024 · CIK: 0001163389 · Accession: 0001903596-24-000615
AI Filing Summary & Sentiment
File numbers found in text: 000-33441
Referenced dates: September 24, 2024
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CORRESP
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filename1.htm
October 11, 2024
Division of Corporate Finance
United States Securities and Exchange
Commission
100 F Street, NE
Washington, DC 20549
Re: New Peoples Bankshares,
Inc.
Form 10-K for Fiscal
Year Ended December 31, 2023
File No. 000-33441
Dear Ms. Brown and Mr. Lopez:
In response to the letter dated September
24, 2024, New Peoples Bankshares, Inc. offers the following reply:
1. We
note the description of your processes for assessing, identifying, and managing material
risks from cybersecurity threats. Please revise to address whether you engage assessors,
consultants, auditors, or other third parties in connection with any such processes. See
Item 106(b)(1)(ii) of Regulation S-K.
We engage various third parties
to assist us in identifying, assessing and responding to cybersecurity threats. This includes around-the-clock managed firewall services
and managed detection and response services provided by various third parties. In addition, we engage third parties to test the vulnerability
of our cybersecurity infrastructure on a regular basis and we have a third-party assessment performed annually.
We will enhance our disclosures
in future filings on Form 10-K to incorporate the above information, as well as any subsequent changes to our procedures, policies or
personnel, as appropriate.
2. We
note your disclosure that your third-party service providers are under constant threat of
cybersecurity attack. Please revise to disclose whether you have processes to oversee and
identify risks from threats associated with your use of such third party services providers.
Refer to Item 106(b)(1)(iii) of Regulation S-K.
We use a variety of methods
and tools to assess a third-party vendor’s controls related to cybersecurity threats, such as obtaining proof a provider’s
independent testing of data protection controls, imposition of contractual obligations and reviews of data protection controls such as
backups, encryption standards and disaster recovery. Our information technology and vendor risk management functions assess information
technology and cybersecurity third party providers as part of the initial determination process and then periodically thereafter. These
third-party service providers are in regular contact with our information technology personnel, and we monitor other sources for information
that any of these providers may have encountered cybersecurity threats.
We will enhance our disclosures
in future filings on Form 10-K to incorporate the above information, as well as any subsequent changes to our procedures, policies or
personnel, as appropriate.
3. We
note that your Information Security Officer is primarily responsible for the cybersecurity
component of your risk management program, which coordinates with the Incident Response Plan
and key members of management. Please revise to provide the relevant expertise of the ISO
and such other persons or members you identify who are responsible for assessing and managing
such risks, in such detail as necessary to fully describe the nature of the expertise. Refer
to Item 106(c)(2)(i) of Regulation S-K.
Our Information Security
Officer has over twenty years of information technology and security experience backed by an undergraduate degree in information
technology and various information technology and network certifications. Aside from the Information Security Officer, cybersecurity
support is provided by our Director of Information Technology who has over twenty-five years of related experience and undergraduate
and post graduate degrees in business engineering and information technology, along with various information technology and network
certifications; and our Chief Information Officer who has twenty years of financial sector information technology and information
security administration and management backed by undergraduate and post graduate degrees in information technology, as well as
various information technology and network certifications, including Certified Information Systems Security Professional
certification.
We will enhance our disclosures
in future filings on Form 10-K to incorporate the above information, as well as any subsequent changes to our procedures, policies or
personnel, as appropriate.
Sincerely,
/s/ Christopher G. Speaks
Christopher G. Speaks
Chief Financial Officer and Executive
Vice President