For months, the Savings and Community Bankers of America has been prodding Eugene A. Ludwig, the comptroller of the currency, to put in place a 1991 law that would reduce the capital thrifts would have to hold against multifamily residential housing loans.

The Savings and Community Bankers organization, which represents 2,000 savings institutions, says if Mr. Ludwig would sign off on the rule it would free up more funds and spur savings institutions to make more affordable-housing loans. The lobbying effort hasn't yet paid off The following letter is an excerpt of the correspondence sent to Mr. Ludwig.from Paul A. Schosberg, president of the organization.

I am writing to urge you to lead the federal banking agencies in taking a timely and important step that could help ease the credit crunch and make more funds available for affordable housing.

This step simply involves carrying out the directive of section 618 of the Resolution Trust Corporation Financing, Restructuring, and Improvement Act of 1991, which provides a capital-related incentive to depository institutions to increase lending for multifamily housing.

By failing to promulgate the required rule, the agencies have missed a valuable opportunity to help achieve the dual objective of increasing general credit availability and addressing affordable-housing needs.

Because statutory and regulatory capital pressures push insured depository institutions away from making multifamily housing loans, the credit crunch in that sector of the economy is exacerbated. I am sure you would agree that a substantial portion of the nation's affordable housing must be addressed in the multifamily sector.

The final rule is long overdue. I hope this proposal will have your most serious and sympathetic consideration.

Paul A. Schosborg President Savings and Community Bankers of America Washington

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