June 18, 2019

Judy Gavant
Executive Vice President and Chief Financial Officer
BAY BANKS OF VIRGINIA INC
1801 Bayberry Court, Suite 101
Richmond, Virginia 23226

       Re: BAY BANKS OF VIRGINIA INC
           Form 10-K
           Filed March 8, 2019
           File No. 000-22955

Dear Ms. Gavant:

      We have reviewed your filing and have the following comment. In our
comment, we
may ask you to provide us with information so we may better understand your
disclosure.

       Please respond to this comment 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 our
comment applies to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to this comment, we may have additional
comments.

Form 10-K filed March 8, 2019

Form 10-K for Fiscal Year Ended December 31, 2018
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Results of Operations, page 31

1.    We note your disclosure on page 34 of the non-GAAP measure "Net Interest
margin
      excluding the effect of acquisition accounting adjustments". We also note
your disclosure
      in your March 31, 2019 earnings press release of the following non-GAAP
measures:
      "ALL plus discounts on acquired loans to gross loans", "Yield on
interest-earning assets,
      excluding accretion of discounts on acquired loans (quarter-to-date
annualized)", "Cost of
      interest-bearing liabilities, excluding amortization of premium on
acquired time deposits
      (quarter-to-date annualized)", and "Core Net interest margin". It appears
that disclosing
      financial measures and metrics excluding the impact of purchase
accounting represents an
      individually tailored recognition and measurement method which could
result in a
      misleading financial metric that violates Rule 100(b) of Regulation G.
Please refer to
      Question 100.04 of the Compliance and Disclosure Interpretations for
guidance.
 Judy Gavant
BAY BANKS OF VIRGINIA INC
June 18, 2019
Page 2
         Therefore, in future filings, including Forms 8-K, please do not
disclose financial
         measures and metrics that exclude the impact of purchase accounting.
        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.

       You may contact William Schroeder, Staff Accountant, at 202-551-3294 or
John Nolan,
Senior Assistant Chief Accountant, at 202-551-3492 if you have questions.



FirstName LastNameJudy Gavant                                  Sincerely,
Comapany NameBAY BANKS OF VIRGINIA INC
                                                               Division of
Corporation Finance
June 18, 2019 Page 2                                           Office of
Financial Services
FirstName LastName