The Federal Home Loan Bank Board is considering legal action against Touche Ross & Co., one of the Big Eight accounting firms, for its part in the failure earlier this year of Beverly Hills Savings & Loan Association, bank board Chairman Edwin J. Gray said yesterday.

Gray told House oversight subcommittee members that the ability to hide the S&L's financial difficulties through accounting changes deterred regulators from acting earlier. Beverly Hills was seized last April 24, but only after its new accountants, Coopers & Lybrand, forced a writedown in loans of close to $100 million, rendering the thrift insolvent.

Gray, meanwhile, did not specify what type of legal action might be taken against Touche Ross. In the past the government has sued accounting firms for what it considered to be misleading accounting practices.

Gray's comments came at the third in a series of House oversight subcommittee hearings on financial accounting and reporting practices. The hearings have been a post mortem on the demise of the country's 37th-largest thrift -- which has cost the government $140 million thus far.

Also during the hearing, members of the subcommittee criticized bank board general counsel Norman H. Raiden, formerly outside counsel for Beverly Hills. Raiden acknowledged he had signed at least 10 documents relating to the thrift association even though he had recused himself from matters involving the S&L before going to work for the bank board.

Gray testified that Beverly Hills was invested primarily in risky real estate joint ventures, in which the thrift put up all the money in the expectation of profiting from a rise in the value of the property. He said the thrift also had made similarly risky acquisition, development and construction loans. In April 1983, some of the financing was reclassified so that the California thrift erroneously reported excessive income while failing to report severe operating losses, he said.

Examiners were aware of difficulties at Beverly Hills as early as 1982, according to bank board documents obtained by the subcommittee. Yet, through the sale of six branch offices and other accounting techniques, the S&L managed to maintain the legal regulatory minimum net worth of 3 percent, although its real net worth was much lower, Gray said. With more than a quarter of the thrift industry showing lower net worth at the time and examiners being in short supply, the bank board did not go after Beverly Hills, he said. (The method of computing regulatory net worth has since been changed.)

In sum, said Gray, "Beverly Hills had an incentive to gamble on the reserves of the FSLIC Federal Savings and Loan Insurance Corp. . The California legislature authorized it to gamble; it did so in inherently risky investments, it compounded the risk by imprudent management practices, it lost huge sums and it hid those losses with the aid of interest reserves and suspect accounting techniques." Gray, who was an executive of a San Diego S&L before becoming a regulator in June 1983, also criticized the short-staffed California Department of Savings and Loan, the primary regulator of the state-chartered thrift, for not doing a better job.

Several subcommittee members criticized Gray's performance. Rep. Ron Wyden (D-Ore.) accused Gray of "lethargic" application of existing regulatory authority and said he opposed granting new powers Gray has requested.

Rep. Thomas A. Luken (D-Ohio) accused Gray of taking a soft attitude toward Beverly Hills while adopting a hard line against privately insured Ohio thrifts by not facilitating their applications for federal insurance during the recent crisis precipitated by the failure of Home State Savings Bank. Luken also accused Gray of being unable to control the situation and challenged him to "do the decent thing and resign."

Attacking Raiden, Wyden and Dingell accused him of conflict of interest. Before his appointment in December 1983, Raiden had been a partner in a law firm representing Beverly Hills.

Wyden detailed bank board documents relating to Beverly Hills that Raiden had signed in 1984 and earlier this year and asked him, "Isn't this at odds with your recusal?"

Wyden and Dingell focused on Raiden's approval of the legality of the S&L's issuance of a $20 million debenture in 1984 that had the effect of increasing the thrift's net worth.

"You are conferring upon them the debenture issue approval," Dingell told Raiden.

"Your signature is all over documents that are material to Beverly Hills Savings & Loan," Wyden added.

Raiden protested that his participation was either of a technical rather than a substantive nature or that the documents were related not to the thrift he once counseled but to its successor established by the bank board.

Raiden also said he had never formalized his recusal for circulation at the bank board but that he had made a sincere effort to avoid conflicts and believed he had been successful.