The Office of Consumer Affairs of the Department of Health, Education and Welfare has taken Citibank to task for an advertisement defining "public interest" which the bank took out in several recent publications, including The Washington Post and The New York Times.

In a letter to Citibank President William Spencer, Acting OCA Director Lee Richardson said that the Citibank description of a true consumer advocate was a "distortion and points to the inherent myopia of having special interest help us conceive of the consumer interest."

Richardson is actively involved in the effots of several federal agencies to secure funding for consumer advocates to appear before agency proceedings.

The ad which in February, is part of a Citibank public relations campaign call "Citiviews." Begun in 1976, the program has published seven different full-page adds.

The ad that inspired Richardson to protest was headlined "The Public Interest" and asked the question, "What, exactly, is The Public?"

The ad implies that to be classified as a consumer advocate, one has to be either a member of a special interest group or an individual expressing a personal view.

"Your definition fits a bank spokesperson," Richardson wrote, "but doesn't reflect a fundamental difference between the world of profit-oriented commercial activity and the democratic expressions of public interests.

"Consumer advocates neither represent themselves nor a special interest," he continued. "They represent everyone in their roles as consumers, a very unspecial interest."

What Citibank, and other severe critics of the consumer movement choose to ignore is that consumer advocates are necessary to achieve and maintain balance in our economic system, Richardson said.

He added. The countervailing force of the consumer is not a threat to the stability of the free market; it is as essential to a functioning marketplace as an advertising campaign and is a lot more useful than a bank's lecture on political science.

In a separate interview, Richardson added that he thought Citibank was trying to show that it is socially responsible enough to address social issues and take a stand, by taking out the ads, but he felt he had to respond, because the issue is big enough.

Citibank spokesman John Williams said that the ads were written by Citibank public relations director Don Colan, and approved by bank officials.

We feel that it is unlike advocacy advertising he said, because it doesn't try to urge a public position. It's actually an attempt to clarify a confusing issue. Public Interest has become a catch phrase that we feel is indiscriminately borrowed to advance various causes. We are trying to simplify public discourse.

He said the bank has not yet decided if it would respond to Richardsons letter.