SecProbe.io

September 16, 2024
J. Todd Scruggs
Secretary, Treasurer and Principal Financial Officer
Bank of the James Financial Group, Inc.
828 Main Street
Lynchburg, VA 24504
Re:Bank of the James Financial Group, Inc.
Form 10-K for Fiscal Year Ended December 31, 2023
File No. 001-35402
Dear J. Todd Scruggs:
            We have limited our review of your filing to the financial statements and related
disclosures and have the following comments.
            Please respond to this letter within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe a
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to this letter, we may have additional comments.
Form 10-K for Fiscal Year Ended December 31, 2023
Management's Discussion and Analysis of Financial Condition and Results of Operations
Analysis of Financial Condition, page 38
1.We note from your tabular disclosure on page 45 that your commercial real estate
(“CRE”) loan portfolio comprised approximately 54.0% of total gross loans, and also in
Note 5 to your consolidated financial statements that the non-owner-occupied CRE loan
class comprised both the largest portion of your CRE, as well as your total loan portfolio,
as of December 31, 2023. Please revise future filings, beginning with your Form 10-Q for
the fiscal quarter ended September 30, 2024, to further disaggregate the composition of
your CRE loan portfolio to more clearly disclose and quantify material geographic and
industry concentrations (e.g., office, retail, multifamily, etc.), as well as current weighted
average and/or range of loan-to-value ratios and occupancy rates, if available, to the
extent material to an investor’s understanding of the credit risk inherent in your CRE
portfolio.
We note your disclosure on page 18 that the deterioration of one or a few of your CRE
loans could cause a significant decline in the related asset quality, as well as your 2.

September 16, 2024
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disclosure that CRE loans represent higher risk and could therefore result in a sharp
increase in loans charged-off. Please revise future filings, beginning with your Form 10-Q
for the fiscal quarter ended September 30, 2024, to describe the specific details of any risk
management policies, procedures or other actions undertaken by management in response
to the current environment.
            In closing, we remind you that the company and its management are responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or
absence of action by the staff.
            Please contact Shannon Davis at 202-551-6687 or Amit Pande at 202-551-3423 with any
questions.
Sincerely,
Division of Corporation Finance
Office of Finance