The lending test would evaluate direct lending as well as indirect lending through participation in loan pools or credit subsidiaries.

James C. Mynatt, spokesman for the newly created loan pool, said he hoped an investigation would not now be needed.

Another $21 million is the "deposit and loan pool," part of which has been lent to needy parishes and may not be repaid, Mr. Ranieri said.

Additional security is provided by letters of credit from a group of banks rated double A, covering 22 percent of the unpaid principal balance of the loan pool.

What's more, fully 35 percent of the most recently issued loan pools in the index have delinquency rates that exceed the target levels specified when they were sold to investors.

Last month, seven New Jersey banks agreed to form a $3.2 million loan pool with which the fund will underwrite more ventures in Camden.

With the cooperation of banks and Westchester County, low-interest loan pools can be created to assist landlords to bring their buildings up to code.

They, with the characteristics of loan pool, can be input to mortgage prepayment model.

Amendments to the Safe Drinking Water Act in the mid-1990's led to similar loan pools for fixing water systems.

The International Monetary Fund's agreement last week to add $60 billion to its loan pool looks as much like the start of a debate as the end.