FOR ALL the complaints about it (including our own), the Election Reform Act has had one immensely positive influence on political campaigns, for which adequate credit has never really been given. As a direct consequence of the law, citizens and voters now are able to know not only from whom candidates for federal office receive their campaign funds but, just as important, what they spend those funds on -- no more hidden support for below-the-belt attacks, while professing only an angelic nature yourself.

It has not always been that way. All advertising material and literature were required to carry legible attribution to the candidate. In addition, the law's insistence on a single campaign bank account made nearly impossible the illegal funneling of funds to others for the underwriting of any dirty tricks. The election reform law has undeniably increased candidate and campaign accountability. And, at the same time, the act has diminished the incidence of unattributed attacks in our campaigns.So far, so good.

But the 1980 campaign saw the arrival full blown on the political stage of independent poltical action committees, whose campaign spending cannot be legally limited. These groups, as long as they are independent of a candidate's formal campaign, can spend as much as they can raise in behalf of, or in opposition to, any candidate for federal office. The richest of these independent groups is the National Conservative Political Action Committee, or Ncpac. NCPAC's approach is familiar: caricaturing the opponent, belting him in ways the candidate himself might not want to risk taking. The candidate who would be the beneficiary of such assistance from an independent group -- if he acknowledges such assistance -- of course runs the risk of being accused of collusion with the group. But under the law, no acknowledgement is necessary. NCPAC, by the way, has already announced plans to start campaigning against Sens. Stafford of Vermont, Chafee of Rhode Island and Bentsen of Texas, among others, by next March.

The First Amendment is not a loophole, and all citizens do have the right to make their views and their opinions known. That is not the question. The question is whether the Election Reform Act, which did encourage a new degree of accountability in political campaigns, should be allowed to become the vehicle for a new cynical, legal fiction -- one that enables candidates to take the lofty high road with full knowledge that lots of help is on the way down below.