United States securities and exchange commission logo





                          December 14, 2023

       Tara Y. Harrison
       Executive Vice President & Chief Financial Officer
       Virginia National Bankshares Corporation
       404 People Place
       Charlottesville, VA 22911

                                                        Re: Virginia National
Bankshares Corporation
                                                            Form 10-K for the
Fiscal Year Ended December 31, 2022
                                                            Response dated
December 1, 2023
                                                            File No. 001-40305

       Dear Tara Y. Harrison:

              We have reviewed your December 1, 2023 response to our comment
letter and have the
       following comment.

              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. Unless
       we note otherwise, any references to prior comments are to comments in
our November 17, 2023
       letter.

       Form 10-K for the Fiscal Year Ended December 31, 2022

       Management's Discussion and Analysis of Financial Condition and Results
of Operations
       Non-GAAP Presentations, page 33

   1.                                                   We note your response
to comment one. In regards to your non-GAAP measure for "ACL
                                                        + fair value mark to
total loans," your adjustment adding the purchase accounting fair
                                                        value marks represents
an individually tailored recognition and measurement method,
                                                        which could result in a
financial measure that violates Rule 100(b) of Regulation
                                                        G. Therefore, please
remove this non-GAAP financial measure from your future filings.
              Please contact Jee Yeon Ahn at 202-551-3673 or Robert Klein at
202-551-3847 if you
       have questions regarding comments on the financial statements and
related matters.
 Tara Y. Harrison
Virginia National Bankshares Corporation
December 14, 2023
Page 2

FirstName LastNameTara Y. Harrison                    Sincerely,
Comapany NameVirginia National Bankshares Corporation
                                                      Division of Corporation
Finance
December 14, 2023 Page 2                              Office of Finance
FirstName LastName