While Michel Camdessus's point that Russia bears the primary responsibility for its situation is irrefutable, his attempt to justify the conduct of the International Monetary Fund in Russia is unconvincing [op-ed, Sept. 13].

For close to 10 years, the IMF has been saying that Russia deserves support because it is sincerely pursuing reform. During that time, as we now know, the Russians have misled the IMF about economic data and misused IMF resources. The IMF is now investigating to see if its money was taken out of the country illegally. Poverty and corruption have reached alarming levels, and the government's failure to collect taxes continues to eat away at its ability to run the country.

Mr. Camdessus's inability to recognize that the IMF's operations in Russia have been a scandalous failure is an example of the culture of unaccountability that pervades the IMF and allows it to continue failed programs, regardless of the adverse consequences for the people affected and without any sense that it owes the public a full explanation for its failures. Fortunately, it is relatively simple to change this situation.

First, the IMF should create an ombudsman's office. The ombudsman would limit investigations to procedural and jurisdictional issues and would not investigate the substance of the policies being followed in the member state. To ensure credibility and independence, the ombudsman would be appointed by and would report directly to the IMF's board. In addition, the ombudsman would issue a public statement at the end of each investigation as well as an annual report.

The ombudsman would offer the IMF board a means for obtaining independent information on how the IMF is actually functioning in its member states and for holding the management and staff accountable. It would also benefit those people and groups who feel that they and their country are being harmed by the IMF's activities.

Second, the IMF should establish a permanent and independent evaluation unit. This unit, like its counterparts at the World Bank and the regional development banks, would investigate completed IMF operations and do cross-country studies of IMF activities. This would enable the IMF staff to learn from their successes and failures and lead to improvements in operations. At a minimum, it should help avoid such spectacular failures as the IMF's operations in Russia.

DANIEL BRADLOW

Washington

The writer is a professor at and director of the International Legal Studies Program at American University.