"Student Deadbeats" {editorial, Sept. 2} acknowledges but fails to emphasize that the growing volume of student loan defaults is a function of the success of the program. The default rate itself has not increased. It has grown in proportion to overall student lending.

It is a serious problem, yet practically no acknowledgment was given to efforts in place to address it. For instance, highly technical regulations require lenders clearly to disclose to students the terms of the debt incurred, to maintain contact with the student for the life of the loan and to engage in collection efforts. Failure to do so nullifies the government's guarantee, shifting the loss to the lender.

Increasing the risk to lenders or states would result in greater care in the lending of money, as asserted in the editorial, but this would mean denying loans to students, or at least to some students -- those attending the "lesser" colleges and proprietary schools or those with poorer grade averages. This "elitist" result is the very antithesis of federal postsecondary education policies.

Banks are not "bluffing" by saying they can't make these loans without the government guarantee. These are typically loans to persons with no income, no job, no credit history, no completed postsecondary education and no assets.

Much needs to be done by lenders, schools and guarantee agencies to address the default problem -- and a great deal is already being done. Sophisticated loan counseling and financial planning programs by all these parties are in place directed at students at every stage of the postsecondary education process. That the default rate has remained basically steady during a tremendous expansion of student credit shows these programs are working. We are all making significant and successful efforts to control the problem and are not fiddling away the hours while Rome burns.

JOE BELEW

resident, Consumer Bankers Association

Arlington