HOT SPRINGS, VA., JUNE 14 -- The Washington Area Bankers Association today disputed the allegation that District banks are not lending enough to the city's economically depressed neighborhoods, saying more than $100 million has been invested in those areas since passage of the D.C. Interstate Banking Act of 1985.

In a 22-page report released at the association's annual convention at the plush resort, The Homestead, the bankers challenged a recently released study by D.C. Banking Superintendent Edward D. Irons that suggested that out-of-state banks that moved into the District have failed to meet community reinvestment commitments. The commitments were made by the banks in exchange for the right to do business in the city.

Although all banks have an obligation under the federal Community Reinvestment Act to make loans wherever they collect deposits, American Security Bank, Citizens Bank of Washington, Dominion Bank, Signet, Crestar and Sovran/D.C. National made specific pledges to invest in the city's poorer areas when they acquired District institutions.

According to the bankers' report, the six banks have invested a total of $261.1 million in all eight wards in the city. That lending activity includes not only single-family loans, which D.C. Banking Superintendent Irons measured, but also small business loans, single-family mortgages, commercial real estate loans and real estate lending to multifamily units. More than 50 percent of the banks' multifamily loans were located in Ward 8, the city's poorest, the study said.

"No one can deny or diminish the positive impact that the banks have had in providing financing for these projects," the study said. "It is difficult to imply redlining when one selectively chooses to only look at single-family mortgage data without the full story of additional housing loans." According to the bankers' report, five of the six banks have exceeded their lending commitments. In one case, American Security, the pledge was exceeded by more than $100 million, the report said. Only Citizens Bank, which promised to lend $15 million over five years, has not exceeded its target.

Irons said he believes the banks have fallen woefully short of meeting the pledges they made, and last month he released data showing the banks invested far more in housing in the city's predominantly white wards than they invested in predominantly black wards.

Although the association did not refute Irons's numbers, their report sharply criticized his study, saying it lacked proper analysis and was meant to imply redlining, the practice of refusing to make loans to areas because of their racial makeup.

"That is simply not happening," said Vicki Tassan, spokeswoman for American Security and author of the association's study.

Irons called the association's attack on his findings "characteristic of the reaction of banks in every major city where documentation of their lending practices have been made public. The kind of study which the Office of Banking issued is not unique."

The bankers' report, which was based on information provided by each institution, was not specific by neighborhood. However, Tassan said the association plans to release future reports that include such an analysis. She said a system should be in place by 1991 that would allow that data to be generated regularly.

Irons said that while he did not wish to denigrate the efforts of the banks, he could not ensure that their figures were an accurate reflection of lending activity. As D.C. banking superintendent, Irons does not have the authority to demand internal lending figures from the banks. The single-family lending figures, on which his study was based, are publicly available.