Credit card company insiders have been unloading their shares in the last few months amid rising concern over consumers' ability to pay off their debt.

Insiders sold 187,375 shares of MBNA Corp. between August and late October, while Advanta insiders sold 154,064 shares and First USA Inc. insiders sold 120,000 shares.

With the notable exception of MBNA - where chairman Alfred Lerner took advantage of a dip in his company's stock in October to buy a million shares at $36.50, building his stake to 13% - the selling far outstripped buying by the credit card company insiders.

Only 10,700 shares MBNA shares were bought by insiders other than Mr. Lerner. Advanta Corp. insiders bought only 297 shares, and no insider buys of First USA were reported.

Robert Gabele, president of CDA/Investnet, which provided the insider transaction data, tied the transactions to the worries about consumer credit quality.

"The underlying message we are getting from insiders at this time is that consumers are not providing a lot of impetus to the economy," Mr. Gabele said. "Since insiders focus on future earnings, not yesterday's, we can only infer that they are not expecting much upside in the consumer picture in the foreseeable future."

That assessment was strongly disputed by Sanford C. Bernstein & Co. analyst Moshe A. Orenbuch. Credit card company executives are paid in large part by stock options, so it is only natural they cash out on some, Mr. Orenbuch argued.

"Every year for the last four years there has been insider selling at these companies, but the stocks are all up," he said.

First USA chief executive John C. Tolleson said he recently bought 5,000 shares, Mr. Orenbuch said.

In late October, however, Mr. Tolleson exercised options on 50,000 shares and sold them. The company's president, Richard W. Vague, exercised options on 50,000 shares, selling them on Oct. 30.

At Advanta, president Richard A. Greenawalt exercised options on 60,000 shares and sold them in September. His 1995 sales now total 110,000 shares. He owns 132,962 shares. Director William Kantor's September sale of 70,000 shares brings his total volume of 1995 selling to 95,000.

At MBNA, vice president John Cochran exercised options on 26,500 shares, and sold 20,000 of them in September. Vice president Ronald Davies exercised options on 90,000 shares in the same month, and sold them. And President Charles Cawley decreased his holdings by 32,025 shares in September.

However, the big news at MBNA was Mr. Lerner's purchase, which increased his ownership to 19.13 million shares in the Newark, Del.-based company.

"Between now and the end of the year, the differences between MBNA and others in the credit card business will become even more apparent than they are now," Mr. Lerner said in a statement at the time.

And Mr. Orenbuch noted that the billionaire chief executive, who ranked 90th on Forbes magazine's 1995 list of the 400 wealthiest Americans, has traditionally bought MBNA shares when the price is low.

Among banks, insider selling continued at a rapid clip, as executives appear concerned this year's stock rally will not persist, Mr. Gabele said.

Insiders at Bankers Trust New York Corp. unloaded 111,820 shares in late October. Retired chief financial officer Timothy Yates sold 77,634 shares, grossing at least $4.9 million.

At Mellon Bank Corp., insiders exercised options on 218,754 shares in late October, and sold 189,872 shares.

At BankAmerica Corp., chief financial officer Lewis Coleman sold 22,000 shares on Oct. 26. Two weeks later he announced he would leave the company.

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