A story in the Oct. 19 Business section "Area CD Rates Highest in Nation; Cause for Concern?" contains errors of fact, makes misleading comparisons and generally leads the reader to false conclusions, at least with regard to NVR Savings Bank. Specifically:

(1) The article references NVR's special rate of 9.4 percent on a 15-month certificate of deposit without indicating that this is a variable-rate certificate or that the special rate is only guaranteed through Dec. 31.

(2) This rate is then compared not with a variable rate but with a 12-month fixed rate.

(3) The reporter speculates about the interest rates offered by NVR and other named institutions: "Not coincidentally, all of these institutions have been hit by the downturn in the area's commercial real estate market." NVR does not invest in commercial real estate, and it has not incurred losses on the commercial real estate loans inherited from its predecessor, McLean Federal Savings and Loan.

(4) The article makes a sneering suggestion that there is something illegitimate or deceptive about our certificate: "Like the Texas CDs of the mid-1980s, local certificates are being cloaked in reassurance, with names like 'Secure CD' from NVR Savings." The advertisement that the reporter is referring to says, in all caps, "DON'T BE TRICKED. TREAT YOURSELF TO A SECURE CD FROM NVR." It does not print "Secure CD" within quotation marks. In other words, we have not named our certificate and do not refer to it in any other way than generically: a 15-month variable-rate certificate.

(5) The comparison of the Washington market with the Texas market of the mid-'80s, which the reporter urges in every way she can, is patently misleading. Although the local commercial real estate market is unquestionably distressed and residential real estate is soft, the whole Washington economy has not collapsed, which was the case in Texas.

The facts are that NVR is profitable ($6.9 million after taxes in 1989, $5.3 million year-to-date after taxes). It comfortably exceeds capital requirements: core capital at 4.72 percent (requirement, 3 percent), tangible capital at 3.81 percent (requirement, 1.5 percent), risk-based capital at 10.17 percent (requirement, 6.4 percent), as of Sept. 30. Its annualized return on average assets as of Sept. 30 was 1.53 percent. The bank invests almost exclusively in single-family residential real estate loans and consumer loans, and it does not make loans to NVR-affiliated building companies. In short, by every objective measure NVR is a healthy bank.

KEVIN J. O'NEIL McLean The writer is president of NVR Savings Bank.