IN RESPONSE to the epidemic of bank failures, the federal bank regulators have been tightening the standards for lending. That's necessary to protect the banking system, but it's also painful. Borrowers accustomed to easy credit are no longer getting it, and they are complaining loudly to their friends in Washington. It's probably true that the comptroller of the currency, Robert L. Clarke, has tightened more than the other federal agencies with which he shares the responsibility for overseeing the banks. That's because the comptroller's standards were, until recently, less rigorous than those of the others -- the Federal Reserve Board and the Federal Deposit Insurance Corp.

As a result of this tightening there now seems to be a campaign under way to deny reappointment to Mr. Clarke, whose term is ending. That campaign is reportedly being led by John Sununu, the president's chief of staff. This would not be an isolated case. Last spring Mr. Sununu tried -- unsuccessfully -- to ease L. William Seidman out of the chairmanship of another of the regulatory agencies, the FDIC.

Mr. Clarke is a capable regulator, and he is entirely on the right track. The accusation against him is that by drawing the rules too tightly, he is creating a shortage of bank credit and aggravating the recession into which the economy is sliding. The answer is that in the great credit-fed boom of the past decade, many banks and many of their customers picked up a lot of bad habits. Breaking those habits will have its costs. But the alternative cost is much higher.

When a bank lends out its depositors' federally insured money, the taxpayer ultimately stands behind the loan whether it's wise or foolish. That's why the S&L catastrophe is now costing taxpayers hundreds of billions of dollars. It happened because a lot of politicians genuinely believed that the construction and real estate industries would fall into deep trouble without a steady flow of easy credit through the S&Ls, and they pressed the S&L regulators to bend the rules and keep those loans flowing. The result has been trouble deeper than anyone, five years ago, would have conceived possible.

The banking system is in better shape than the S&L industry. But bank failures have been averaging about a dozen a month, and the federal deposit insurance fund has been running serious losses. One big failure could wipe it out and throw the insurance costs directly onto the taxpayer, as in the S&L affair. It's not a good time to run a campaign from the White House against the regulators who are trying to tighten up and protect the public.