I strongly reject Freddie Mac's assertion that the reason African Americans own fewer homes than whites is that they have "bad credit" ["Racial Disparity Found in Credit Rating," front page, Sept. 21].

I take exception to Freddie Mac's methodology, insensitivity and lack of care in drawing conclusions that are not supported by its own slip-shod data.

The timing of the release of Freddie Mac's study raises questions in my mind about whether Freddie Mac is attempting to counter the release of two recent studies of discrimination in mortgage lending--one by ACORN and another by the Urban Institute. The Urban Institute study was commissioned by the U.S. Department of Housing and Urban Development.

The two studies concluded that minority home buyers in the United States do face discrimination from mortgage lending institutions. The Urban Institute's study found minorities were less likely to receive information about loan products, received less time and information from loan officers and were quoted higher interest rates in most of the cities where tests were conducted. Analysis of data assembled by the Federal Reserve Bank of Boston finds large differences in loan denial rates between minority and white applicants, other things being equal.

Freddie Mac's study indicated that 72 percent of white households own homes compared with 46 percent of African Americans. But Freddie Mac did not discuss discrimination in employment or disparity in income, which are well documented by the other studies. Rather, Freddie Mac chose to pinpoint "bad credit" as the reason for the disparity in homeownership. "Bad credit" as defined by whom or determined by whom--the same lenders who have been found to discriminate against African Americans?

I am also concerned about what is implied by Freddie Mac's statement that income alone does not explain this disparity and that--in the $65,000 to $75,000 bracket--34 percent of African American borrowers have bad credit compared with 20 percent of white borrowers. In other words, we are a credit risk because no matter how much money we make, we are too stupid and undisciplined to know how to spend, plan and save.

Freddie Mac conveniently left out the following factors--among others--that clearly demonstrate that African Americans and whites are not similarly situated in this society, especially not in the world of credit.

* The hourly earnings of African American men are 65 percent of those of white men.

* African American men work 77 percent as many hours as white men.

* African American men will pay more than $1,000 more for the same new car as white men.

If Freddie Mac wants to do right by African Americans, then it can do more than just teach us about good credit. It can become a leader in discouraging discretionary practices employed by lending officers to deny African Americans and other people of color equal opportunity.

--Maxine Waters

The writer is a Democratic representative from California.