August 19, 2005

Division of Corporation Finance
Securities and Exchange Commission
Mail Stop 4561
450 Fifth Street, N.W.
Washington, DC 20549

Attn: Mr. Don Walker
      Senior Assistant Chief Accountant

                             Re: Exchange National Bancshares, Inc.
                                 Form 10-K for the year ended December 31, 2004
                                 SEC File No. 000-23636

Dear Mr. Walker:

            We are writing in response to your letter dated August 9, 2005, with
respect to the above-referenced report filed by Exchange National Bancshares,
Inc. (the "Company"). Our numbered responses to your comments correspond to the
numbered comments in your letter.(1)

            In responding to your comments, we acknowledge that:

                  -     the Company is responsible for the adequacy and accuracy
                        of the disclosure in our filing with the Commission;

- -----------

(1)   A complete response to the numbered comments in your letter would call for
      the disclosure of information that is covered by one or more exemptions in
      the Freedom of Information Act. In particular, 17 C.F.R. Section
      200.80(b)(4) exempts disclosure of trade secrets and commercial or
      financial information which are privileged or confidential. In accordance
      with the Freedom of Information Act, the privileged or confidential
      information has been omitted from this response letter and is being
      furnished to the Office of Freedom of Information Act and Privacy
      Operations concurrently with the filing of this response letter. Each
      instance in which privileged or confidential information has been omitted
      from this response letter has been identified herein by footnote. We have
      sent to you a paper copy of the Company's FOIA Confidential Treatment
      Request, including the privileged or confidential information to which it
      refers.



Division of Corporation Finance
Attn: Mr. Don Walker
Page 2

                  -     staff comments or changes to disclosure in our filing
                        made in response to staff comments do not foreclose the
                        Commission from taking any action with respect to the
                        filing; and

                  -     the Company may not assert staff comments as a defense
                        in any proceeding initiated by the Commission or any
                        person under the federal securities laws of the United
                        States.

                                    COMMENTS

COMMENT 1  PLEASE TELL US WHAT EFFECT THE CHANGES IN ASSET QUALITY OF THE LOAN
           PORTFOLIO, SPECIFICALLY BUT NOT LIMITED TO THE INCREASE IN
           COMMERCIAL, FINANCIAL AND AGRICULTURAL LOANS, THE INCREASED
           CHARGE-OFFS, AND DECREASED RECOVERIES, HAVE HAD ON YOUR DETERMINATION
           OF THE ALLOWANCE ALLOCATION AND PROVISION FOR 2004.

           The increase in our nonaccruals from December 31, 2003 to December
           31, 2004 was primarily the result of two credits. One was to
           [____________](2) which had balances of $1,137,000 and $2,070,000 at
           December 31, 2003 and December 31, 2004, respectively. This credit
           was on nonaccrual at December 31, 2003 and management allocated
           $341,000 of the allowance at December 31, 2003 to this credit. This
           credit increased $933,000 from December 31, 2003 to December 31,
           2004, but due to the nature of the collateral securing this increase,
           management did not feel that an additional allowance allocation was
           warranted. Our reasons for making these additional advances are
           discussed in Comment 5. The second credit, which increased our
           nonaccruals, from December 31, 2003 to December 31, 2004, was a
           $1,500,000 loan to [____________](3). This loan was not on nonaccrual
           as of December 31, 2003. Management allocated $750,000 of the
           allowance at December 31, 2004 to this credit.

           While nonaccruals did increase $2,700,000 from 2003 to 2004, at the
           same time, our other classified loans decreased from $17,167,000 at
           December 31, 2003 to $12,438,000 at December 31, 2004. The allowance
           allocation related to our

- -----------

(2)   A complete response to this Comment would call for the disclosure of
      information that is covered by one or more exemptions in the Freedom of
      Information Act. In accordance with the Freedom of Information Act, we
      have omitted from this response letter trade secrets and commercial or
      financial information which are privileged or confidential. Such
      information is included in the Company's FOIA Confidential Treatment
      Request in the attachment identified with the following Identifying Number
      and Code: ENB-1.

(3)   A complete response to this Comment would call for the disclosure of
      information that is covered by one or more exemptions in the Freedom of
      Information Act. In accordance with the Freedom of Information Act, we
      have omitted from this response letter trade secrets and commercial or
      financial information which are privileged or confidential. Such
      information is included in the Company's FOIA Confidential Treatment
      Request in the attachment identified with the following Identifying Number
      and Code: ENB-2.



Division of Corporation Finance
Attn: Mr. Don Walker
Page 3

           classified loans decreased $709,000 from 2003 to 2004, which
           essentially offset the $750,000 increase in the allowance allocated
           to [____________](4) discussed above.

           Total net charge-offs increased $1,555,000 from $158,000 during 2003
           to $1,713,000 during 2004 primarily due to one credit. Of the
           $1,713,000 of charge-offs during 2004, $1,545,000 related to this one
           credit for which management had allocated $834,000 of the allowance
           at December 31, 2003.

           In summary, management reviews the adequacy of the allowance for loan
           losses and the related provision on a quarterly basis taking into
           consideration nonaccrual loans, internally classified loans,
           charge-offs and the related allocations of the allowance to these
           credits. Management then makes a determination as to whether the
           allowance is sufficient to cover probable losses on these credits or
           whether the allowance needs to be increased by additional provisions
           to the allowance for loan losses. Management's determination was that
           the provision for 2004 was adequate to maintain the allowance for
           loan losses at a level sufficient to cover probable future losses in
           the loan portfolio at December 31, 2004.

COMMENT 2  PLEASE DESCRIBE FOR US ANY UNDERSTANDINGS OR AGREEMENTS YOU MAY HAVE
           WITH YOUR REGULATORS CONCERNING FUTURE CHANGES IN YOUR LEVELS OF LOAN
           LOSS PROVISION AND ALLOWANCE.

           Our Company and subsidiary banks have no understandings or agreements
           with any of our regulators concerning future changes in our levels of
           loan loss provision and allowance.

COMMENT 3  PLEASE PROVIDE US DETAILED INFORMATION ON THE LOANS COMPRISING THE
           $1.6 MILLION COMMERCIAL, FINANCIAL AND AGRICULTURAL LOANS CHARGED OFF
           FOR 2004, INCLUDING BUT NOT LIMITED TO THE SIZE, TYPE AND HISTORIC
           CIRCUMSTANCES SURROUNDING THE DECLINE IN THE ASSET QUALITY OF THE
           LOANS.

           $1,545,000 of the $1,596,000 of commercial, financial and
           agricultural loans charged off in 2004 represents borrowings of one
           customer. The customer is [____________](5). The loan to this
           customer has been internally classified as

- -----------

(4)   A complete response to this Comment would call for the disclosure of
      information that is covered by one or more exemptions in the Freedom of
      Information Act. In accordance with the Freedom of Information Act, we
      have omitted from this response letter trade secrets and commercial or
      financial information which are privileged or confidential. Such
      information is included in the Company's FOIA Confidential Treatment
      Request in the attachment identified with the following Identifying Number
      and Code: ENB-3.

(5)   A complete response to this Comment would call for the disclosure of
      information that is covered by one or more exemptions in the Freedom of
      Information Act. In accordance with the Freedom of Information Act, we



Division of Corporation Finance
Attn: Mr. Don Walker
Page 4

           Substandard since the fourth quarter of 2002. During the first
           quarter of 2004, our Company placed the loan on nonaccrual when the
           liquidation value of our collateral did not appear to be sufficient
           to cover our principal and interest and the customer was experiencing
           cash flow problems. The customer was receiving what appeared to be
           profitable orders with prospects for more and they were in serious
           talks with several potential investors that, had their investments
           come to fruition, would have repaid our loans in their entirety.
           Although the loans were classified and on nonaccrual, we continued to
           make new advances to allow them to build product to fill incoming
           orders. During this period, the customer started a new division which
           looked as though it had promise and might, in conjunction with new
           sales orders, return the company to profitability. In the fourth
           quarter of 2004 one of the key principals of the new division died
           unexpectedly. With the death of this individual, the prospect of
           attracting venture capital was significantly diminished. As a result,
           we began to seriously question the customer's ability to turn the
           company around and continue as a going concern. We made the decision
           that we could no longer continue to provide financing to the customer
           and made demand on our notes. As a result, the customer went out of
           business and we began to liquidate and realize upon our collateral
           and we charged off $1,545,000 during the fourth quarter.

COMMENT 4  PLEASE TELL US HOW MUCH SPECIFIC LOAN LOSS ALLOWANCE HAD BEEN
           ESTABLISHED PRIOR TO 2004 FOR EACH OF THE LOANS COMPRISING THE $1.6
           MILLION OF COMMERCIAL, FINANCIAL AND AGRICULTURAL LOANS CHARGED OFF
           IN 2004.

           As of December 31, 2003 we had allocated $903,000 of our allowance
           for loan losses to the loans which were charged off in 2004.

COMMENT 5  PLEASE PROVIDE US WITH THE TYPE AND SIZE OF LOANS COMPRISING THE
           INCREASE OF $2.7 MILLION IN THE COMMERCIAL, FINANCIAL, AND
           AGRICULTURAL CLASSIFICATION OF THE NONACCRUAL LOANS TABLE FOR 2004.
           IDENTIFY HOW MUCH, IF ANY, SPECIFIC LOAN LOSS ALLOWANCE HAS BEEN
           RECORDED FOR EACH OF THESE LOANS.

           The $2.7 million increase in nonaccrual commercial, financial, and
           agricultural loans in 2004 was primarily represented by three
           credits. The first credit represents additional advances of $933,000
           to [____________](6), discussed in Comment 1 above, in order to
           assist the customer in returning the business to

- ----------

      have omitted from this response letter trade secrets and commercial or
      financial information which are privileged or confidential. Such
      information is included in the Company's FOIA Confidential Treatment
      Request in the attachment identified with the following Identifying Number
      and Code: ENB-4.

(6)   A complete response to this Comment would call for the disclosure of
      information that is covered by one or more exemptions in the Freedom of
      Information Act. In accordance with the Freedom of Information Act, we
      have omitted from this response letter trade secrets and commercial or
      financial information which are privileged or confidential. Such
      information is included in the Company's FOIA Confidential Treatment
      Request in the attachment identified with the following Identifying Number
      and Code: ENB-5.



Division of Corporation Finance
Attn: Mr. Don Walker
Page 5

           profitability. This customer had nonaccrual loan balances of
           $2,070,000 at December 31, 2004 compared to $1,137,000 at December
           31, 2003. $310,500 of the allowance was allocated to this credit at
           December 31, 2004.

           The second credit of $364,000 represents the residual debt of
           [____________](7) discussed in Comment 3 above. We anticipate this
           credit, net of the allocated allowance of $55,000, will be paid off
           from the proceeds received from the liquidation of collateral.

           The third credit of $1,500,000, discussed in Comment 1 above,
           represents a loan to [____________](8). We are currently holding $1.2
           million of cash collateral; however, we are currently defending our
           collateral position in Chapter 11 bankruptcy court. $750,000 of the
           allowance was allocated to this credit at December 31, 2004.

            We hope that the above has been of assistance to you and that it is
fully responsive to your comments. If you have any questions or require any
further information, please call me at (660) 885-2241.

                                         Very truly yours,

                                         James E. Smith
                                         Chairman and CEO

cc: Ms. Paula Smith

- -----------

(7)   A complete response to this Comment would call for the disclosure of
      information that is covered by one or more exemptions in the Freedom of
      Information Act. In accordance with the Freedom of Information Act, we
      have omitted from this response letter trade secrets and commercial or
      financial information which are privileged or confidential. Such
      information is included in the Company's FOIA Confidential Treatment
      Request in the attachment identified with the following Identifying Number
      and Code: ENB-6.

(8)   A complete response to this Comment would call for the disclosure of
      information that is covered by one or more exemptions in the Freedom of
      Information Act. In accordance with the Freedom of Information Act, we
      have omitted from this response letter trade secrets and commercial or
      financial information which are privileged or confidential. Such
      information is included in the Company's FOIA Confidential Treatment
      Request in the attachment identified with the following Identifying Number
      and Code: ENB-7.


                                                              September 16, 2005

Division of Corporation Finance
Securities and Exchange Commission
Mail Stop 4561
450 Fifth Street, N.W.
Washington, DC 20549

Attn:    Mr. Don Walker
         Senior Assistant Chief Accountant

                                        Re: Exchange National Bancshares, Inc.
                                            Form 10-K for the year
                                            ended December 31, 2004
                                            SEC File No. 000-23636

Dear Mr. Walker:

             We are writing in response to your letter dated September 2,
2005, with respect to the above referenced report filed by Exchange National
Bancshares, Inc. (the "Company"). Our numbered response to your comment
corresponds to the numbered comment in your letter.(1)

             In responding to your comment, we acknowledge that:

- ----------------

(1)   A complete response to the numbered comments in your letter would call for
      the disclosure of information that is covered by one or more exemptions in
      the Freedom of Information Act. In particular, 17 C.F.R. Section
      200.80(b)(4) exempts disclosure of trade secrets and commercial or
      financial information which are privileged or confidential. In accordance
      with the Freedom of Information Act, the privileged or confidential
      information has been omitted from this response letter and is being
      furnished to the Office of Freedom of Information Act and Privacy
      Operations concurrently with the filing of this response letter. Each
      instance in which privileged or confidential information has been omitted
      from this response letter has been identified herein by footnote. We have
      sent to you a paper copy of the Company's FOIA Confidential Treatment
      Request, including the privileged or confidential information to which it
      refers.



                    -   the Company is responsible for the adequacy and accuracy
                        of the disclosure in our filing with the Commission;

                    -   staff comments or changes to disclosure in our filing
                        made in response to staff comments do not foreclose the
                        Commission from taking any action with respect to the
                        filing;

                    -   the Company may not assert staff comments as a defense
                        in any proceeding initiated by the Commission or any
                        person under the federal securities laws of the United
                        State; and

                    -   the Company is aware of the requirements as set forth in
                        the FFIEC Policy Release on Allowances for Loan and
                        Lease Losses dated July 2, 2001 and our methodology and
                        documentation complies with this statement.

                                     COMMENT

COMMENT 1   PLEASE PROVIDE US WITH A QUANTITATIVE AND QUALITATIVE ANALYSIS WHICH
            SHOWS HOW YOU APPLIED YOUR ALLOWANCE METHODOLOGY TO LOANS NOT
            IMPAIRED IN A CONSISTENT FASHION AT EACH OF DECEMBER 31, 2004 AND
            DECEMBER 31, 2003. YOUR ANALYSIS SHOULD CLEARLY DEMONSTRATE HOW YOU
            DETERMINED THAT THE DECEMBER 31, 2004 ALLOWANCE AND THE RELATED
            PROVISION FOR THE YEAR OF $942,000 WERE APPROPRIATE. IN YOUR
            RESPONSE, CONSIDER THE DOCUMENTATION REQUIREMENTS SET FORTH IN THE
            FFIEC POLICY RELEASE ON ALLOWANCES FOR LOAN AND LEASE LOSSES DATED
            JULY 2, 2001.

            Our Company follows an allowance for loan losses methodology that
            categorizes loans as impaired, substandard with no specific
            allocation, substandard with specific allocations, special mention,
            watch, and non-classified. That methodology has been followed
            consistently by our Company for approximately eight years. This
            methodology requires that all loans be graded and reserve
            percentages established based upon those grades. If warranted by the
            situation, specific reserve allocations may be established for
            individual loans based upon specific analysis of the facts and
            circumstances regarding those loans. Reserves for loans not
            subjected to specific analysis are established using pre-established
            ratios which are based upon standard bank regulatory classification
            percentages as well as average historical loss percentages. The
            attached schedules quantitatively summarize the ratings and related
            reserve allocations as of December 31, 2004 and 2003.

            The attached analyses show that even though impaired loans increased
            from the prior period, total classified loans (impaired, substandard
            with no specific allocation, and substandard with specific
            allocation) decreased substantially from approximately $19,558,000
            at December 31, 2003 to



            approximately $15,857,000 at December 31, 2004 with a resulting
            $632,000 decrease in the required reserve allocation for these
            credits.

            As can be seen from the analyses, substandard loans with no specific
            allocation (which are not considered to be impaired loans) decreased
            $7,066,000 from $15,188,000 at December 31, 2003 to $8,122,000 at
            December 31, 2004 with a corresponding decrease of $1,394,000 in the
            related allowance allocation. Substandard loans with specific
            allocation (which are also not considered to be impaired loans)
            increased from $1,084,000 at December 31, 2003 to $2,235,000 at
            December 31, 2004. However, based upon specific reviews of these
            loans and taking into consideration both percentage and specific
            allocations based upon collateral valuations, the required allowance
            allocation related to these loans decreased by $235,000 at December
            31, 2004. A detailed discussion of the credits associated with the
            increase in impaired loans as well as the increase in charge-offs
            during 2004 and the related allowance for loan loss allocations
            related to those credits was contained in our previous letter, dated
            August 19, 2005.

            As can also be seen in the analyses, non-classified loans had
            allocation percentages of approximately 0.50% during both periods.
            Watch loans, which also would be considered non-impaired loans, had
            allocation percentages of approximately 1.00% for both periods.
            Management allocated $3,013,000 of the allowance to non-classified
            loans of $603,209,000 at December 31, 2004 and allocated $2,730,000
            of the allowance to non-classified loans of $551,014,000 at December
            31, 2003. $153,000 of the allowance was allocated to watch loans of
            $15,284,000 at December 31, 2004 with $121,000 allocated to watch
            loans of $12,001,000 at December 31, 2003.

            The unallocated portion of the allowance (the balance of the
            allowance in excess of the specific allocations plus the percentage
            allocations) decreased approximately $472,000 from December 31, 2003
            to December 31, 2004. The unallocated portion of the allowance was
            $989,000 at December 31, 2003 versus $516,000 at December 31, 2004.

            The unallocated portion of the allowance is based on management's
            evaluation of conditions that are not directly reflected in the
            determination of the formula and specific allowances discussed
            above. The evaluation of inherent loss with respect to these
            conditions is subject to a higher degree of uncertainty because they
            may not be identified with specific problem credits or portfolio
            segments. Conditions evaluated in connection with the unallocated
            portion of the allowance include general economic and business
            conditions affecting our key lending areas, credit quality trends
            (including trends in substandard loans expected to result from
            existing conditions), collateral values, specific industry
            conditions within portfolio segments, bank regulatory examination
            results, and findings of our internal loan review department.


            Management was seeing encouraging developments in the financial
            performance of some large credits rated substandard but not
            impaired. In addition, our Company's subsidiary banks have been the
            subject of ongoing, routine examinations by their respective
            regulators. In the most recent examinations regulators found that
            [____________](2) In light of these circumstances, management felt
            that the unallocated portion of the allowance at December 31, 2004,
            although lower than the December 31, 2003 balance, was at an
            acceptable level to cover the inherent loss not identified by the
            formula and specific allocations of the allowance.

            In conclusion, as a result of having previously allocated reserves
            to cover the increased charge-offs taken during 2004, the reduction
            in total classified loans at December 31, 2004, the improvements in
            the financial performance of some large substandard credits, and
            satisfactory examination results with respect to the allowance for
            loan loss, management feels that the provision for loan losses
            recorded for fiscal year 2004 was adequate and proper.

            We hope that the above has been of assistance to you and that it is
fully responsive to your comments. If you have any questions or require any
further information, please call me at (660) 885-2241.

                                                     Very truly yours,

                                                     James E. Smith
                                                     Chairman and CEO

Enclosure

cc:   Ms. Paula Smith

- ----------------

(2)  A complete response to this Comment would call for the disclosure of
     information that is covered by one or more exemptions in the Freedom of
     Information Act. In accordance with the Freedom of Information Act, we have
     omitted from this response letter trade secrets and commercial or financial
     information which are privileged or confidential. Such information is
     included in the Company's FOIA Confidential Treatment Request in the
     attachment identified with the following Identifying Number and Code:
     ENB-8.



                               Exchange Bancshares

                          Reserve Allocation Worksheet
                                    12/31/03

[____________](3)

- ----------------

(3)   A complete response to this Comment would call for the disclosure of
     information that is covered by one or more exemptions in the Freedom of
     Information Act. In accordance with the Freedom of Information Act, we have
     omitted from this response letter trade secrets and commercial or financial
     information which are privileged or confidential. Such information is
     included in the Company's FOIA Confidential Treatment Request in the
     attachment identified with the following Identifying Number and Code:
     ENB-9.



                               Exchange Bancshares

                          Reserve Allocation Worksheet
                                    12/31/04

[____________](4)

- ----------------

(4)  A complete response to this Comment would call for the disclosure of
     information that is covered by one or more exemptions in the Freedom of
     Information Act. In accordance with the Freedom of Information Act, we have
     omitted from this response letter trade secrets and commercial or financial
     information which are privileged or confidential. Such information is
     included in the Company's FOIA Confidential Treatment Request in the
     attachment identified with the following Identifying Number and Code:
     ENB-10.



                                                                October 25, 2005

Division of Corporation Finance
Securities and Exchange Commission
Mail Stop 4561
450 Fifth Street, N.W.
Washington, DC 20549

Attn: Mr. Don Walker
      Senior Assistant Chief Accountant

                             Re: Exchange National Bancshares, Inc.
                                 Form 10-K for the year ended December 31, 2004
                                 SEC File No. 000-23636

Dear Mr. Walker:

            We are writing in response to your letter dated October 11, 2005,
with respect to the above referenced report filed by Exchange National
Bancshares, Inc. (the "Company"). Our numbered responses to your comments
correspond to the numbered comments in your letter.(1)

                                     COMMENT

COMMENT 1 PLEASE TELL US:

            -     YOUR RATIONALE FOR CATEGORIZING THE LOANS AS "SUBSTANDARD"
                  VERSUS "IMPAIRED" GIVEN THE SIGNIFICANT ALLOWANCE TO LOAN
                  BALANCE RATIOS, AND

- ----------

(1)   A complete response to the numbered comments in your letter would call for
      the disclosure of information that is covered by one or more exemptions in
      the Freedom of Information Act. In particular, 17 C.F.R. Section
      200.80(b)(4) exempts disclosure of trade secrets and commercial or
      financial information which are privileged or confidential. In accordance
      with the Freedom of Information Act, the privileged or confidential
      information has been omitted from this response letter and is being
      furnished to the Office of Freedom of Information Act and Privacy
      Operations concurrently with the filing of this response letter. Each
      instance in which privileged or confidential information has been omitted
      from this response letter has been identified herein by footnote. We have
      sent to you a paper copy of the Company's FOIA Confidential Treatment
      Request, including the privileged or confidential information to which it
      refers.



Division of Corporation Finance
Attn: Mr. Don Walker
Page 2

            -     HOW YOU APPLIED SFAS 114 PARAGRAPHS 12 - 16 AND SFAS 118
                  PARAGRAPH 6 IN YOUR IMPAIRED LOAN DISCLOSURES.

            Management uses the guidance provided in paragraphs 8 - 10 of SFAS
            114 to determine if a loan is impaired. The $2,235,000 of
            substandard loans and the related $849,000 loan loss allocation at
            December 31, 2004 and the $1,401,000 substandard loans and the
            related $1,084,000 loan loss allocation at December 31, 2003 were
            loans that were making principal and interest payments in accordance
            with the contractual terms of the loan agreements. None of the loans
            had been restructured or placed on non-accrual status. In addition,
            management believed that, at those times, it was probable that all
            cash amounts owed under the terms of the contracts would be
            collected thus; the loans were not classified as impaired under SFAS
            114.

            However, there were certain weaknesses and concerns about those
            loans. The majority of the loan balances at both dates were
            represented by three loans. These three loans were made to
            [____________](2). In light of economic conditions that existed at
            those times (which included [____________](3)), management believed
            it prudent to establish a reserve allocation for each of these loans
            in accordance with SFAS 5, Accounting for Contingencies.
            Management's reserve methodology has been consistently applied in
            accordance with the FFIEC Policy Release on Allowances for Loan and
            Lease Losses dated July 2, 2001.

            The ratios of allowance allocation to loan balances, under the
            category "substandard loans with specific allocation" we previously
            reported to you, were not necessarily the entire balances of the
            relationships. Management segregated a portion of each relationship
            and applied our allocation to the segregated balances. The total
            reserve allocation as a percentage of the total indebtedness of
            these particular customers was 32.0% of the $4,865,000 total
            relationship balance at December 31, 2003 and 25.7% of the
            $4,061,000 total relationship balance at December 31, 2004.

- ------------

(2)   A complete response to this Comment would call for the disclosure of
      information that is covered by one or more exemptions in the Freedom of
      Information Act. In accordance with the Freedom of Information Act, we
      have omitted from this response letter trade secrets and commercial or
      financial information which are privileged or confidential. Such
      information is included in the Company's FOIA Confidential Treatment
      Request in the attachment identified with the following Identifying Number
      and Code: ENB-11.

(3)   A complete response to this Comment would call for the disclosure of
      information that is covered by one or more exemptions in the Freedom of
      Information Act. In accordance with the Freedom of Information Act, we
      have omitted from this response letter trade secrets and commercial or
      financial information which are privileged or confidential. Such
      information is included in the Company's FOIA Confidential Treatment
      Request in the attachment identified with the following Identifying Number
      and Code: ENB-12.



Division of Corporation Finance
Attn: Mr. Don Walker
Page 3

            In the case of the three loans described above, two eventually
            became impaired. As discussed in our previous responses, in 2004 we
            charged off $1,545,000 of the loan to [____________](4), of which we
            had reserved $584,000 at December 31, 2003. In the case of
            [____________](5), we charged off a portion of this $2,457,000
            credit in 2005, of which $500,000 had been reserved at December 31,
            2004. Additionally in accordance with Securities Act Guide 3, Item
            III.C.2., (Potential Problem Loans), these loans were disclosed in
            our management's discussion and analysis for the years ended
            December 31, 2003 and 2004 as being classified by management as
            having more than normal risk which raised doubts as to the ability
            of the borrower to comply with present repayment terms.

            As stated in our response dated September 16, 2005, our Company's
            banks have been the subject of ongoing, routine examinations by
            their respective regulators and in the most recent examinations
            regulators found that [____________](6).

            In accordance with SFAS 114 paragraphs 12 - 16, once a loan has been
            determined to be impaired (as defined by paragraph 8 of SFAS 114),
            management generally measures impairment based upon the fair value
            of the underlying collateral. In general, market prices for loans in
            our portfolio are not available, and we have found the fair value of
            the underlying collateral to be more readily available and reliable
            than discounting expected future cash flows to be received. Once a
            fair value of collateral has been determined and the impairment
            amount calculated, a specific reserve allocation is made if the
            impairment amount exceeds the historical percentage allocation.

            In accordance with paragraph 6 of SFAS 118, for loans identified as
            impaired, management discloses in our financial statements the
            recorded investment in impaired loans, the allowance for loan losses
            on impaired loans, the amount of

- -------------

(4)   A complete response to this Comment would call for the disclosure of
      information that is covered by one or more exemptions in the Freedom of
      Information Act. In accordance with the Freedom of Information Act, we
      have omitted from this response letter trade secrets and commercial or
      financial information which are privileged or confidential. Such
      information is included in the Company's FOIA Confidential Treatment
      Request in the attachment identified with the following Identifying Number
      and Code: ENB-13.

(5)   A complete response to this Comment would call for the disclosure of
      information that is covered by one or more exemptions in the Freedom of
      Information Act. In accordance with the Freedom of Information Act, we
      have omitted from this response letter trade secrets and commercial or
      financial information which are privileged or confidential. Such
      information is included in the Company's FOIA Confidential Treatment
      Request in the attachment identified with the following Identifying Number
      and Code: ENB-14.

(6)   A complete response to this Comment would call for the disclosure of
      information that is covered by one or more exemptions in the Freedom of
      Information Act. In accordance with the Freedom of Information Act, we
      have omitted from this response letter trade secrets and commercial or
      financial information which are privileged or confidential. Such
      information is included in the Company's FOIA Confidential Treatment
      Request in the attachment identified with the following Identifying Number
      and Code: ENB-15.



Division of Corporation Finance
Attn: Mr. Don Walker
Page 4

            impaired loans with no specific allowance, the average balance of
            impaired loans for the period presented, the income actually
            recognized on impaired loans, and the amount of income that would
            have been recognized had all interest payments been received.

            We hope that the above has been of assistance to you and that it is
fully responsive to your comments. If you have any questions or require any
further information, please call me at (660) 885-2241, or we would be happy to
meet with you in person to discuss any further comments or issues.

                                Very truly yours,

                                James E. Smith
                                Chairman and CEO

enclosure
cc: Ms. Paula Smith


                                                               December 13, 2005

Division of Corporation Finance
Securities and Exchange Commission
Mail Stop 4561
450 Fifth Street, N.W.
Washington, DC 20549

Attn: Mr. Don Walker
      Senior Assistant Chief Accountant

                              Re: Exchange National Bancshares, Inc.
                                  Form 10-K for the year ended December 31, 2004
                                  SEC File No. 000-23636

Dear Mr. Walker:

            We are writing in response to our recent conference call on November
22, 2005, with respect to the above referenced report filed by Exchange National
Bancshares, Inc. (the "Company").

            As a result of the discussions held with you and your staff during
the above referenced phone call, we have undertaken a review of the data
supporting our impaired loan disclosures included in our December 31, 2004 Form
10-K. This review was undertaken in order to determine whether any of the loans
that we reported in the two substandard categories in our reserve allocation
worksheet provided in our correspondence of September 16, 2005 should have in
fact been reported as impaired under paragraph 8 of FAS114, Accounting by
Creditors for Impairment of a Loan.

            We have determined that the $2,234,777 reported as substandard with
specific allocation should have been reported as impaired. In addition,
$2,510,783 of the $8,121,791 originally shown as substandard with no specific
allocation should have been reported as impaired. Therefore the correct amount
of impaired loans at December 31, 2004 was $10,246,426 with a related reserve
allowance of $2,907,142. There were no impaired loans at December 31, 2004 for
which we had made no reserve allowance allocation.

            We have established procedures to identify impaired loans and
measure the level of impairment in accordance with the provisions of FAS114. Our
December 31, 2005 disclosure



Division of Corporation Finance
Attn: Mr. Don Walker
Page 2

will comply with the provisions of FAS114 and our December 31, 2004 data
reported in the 2005 year-end disclosure will reflect the amounts discussed in
the prior paragraph. In addition, we will strive to enhance our Management
Discussion and Analysis in our periodic filings as it relates to our discussion
of our loan loss reserve analysis and methodology.

            We hope that the above has been of assistance to you and that it is
fully responsive to your comments. If you have any questions or require any
further information, please call me at (660) 885-2241, or we would be happy to
meet with you in person to discuss any further comments or issues.

                                             Very truly yours,

                                             James E. Smith
                                             Chairman and CEO

enclosure
cc: Ms. Paula Smith