Beginning in November students may be able to examine all school records kept on them within 45 days of making a formal request.

The Administration is now discussing the implementation of federal legislation enacted in August requiring schools to make available students' files--on pain of losing federal funds--to parents of students under the age of eighteen and students over the age of eighteen or in post-secondary school.

Questions raised by the legislation include what procedures to use in providing access to files, whether any items in current files should be removed, and whether any items are exemptible. Faculties, departments and offices are also considering whether they will modify their record-keeping procedures.

The legislation, part of an amendment to the education bill signed by President Ford last month, also forbids schools to release information from the files, except to designated school officials, without the student's written consent.

Schools receiving federal funds are required to inform students of their right to see their records, as well as to provide opportunities for the correction of inaccurate or misleading data and for hearings to challenge the content of records.

Daniel Steiner '54, general counsel to the University, said last week that he will write Harvard's guidelines for compliance after he has received comments from the deans of all the faculties. He has asked each faculty to report this month what records it has that may be subject to the law and what problems of interpretation may arise.

The Department of Health, Education and Welfare, charged with enforcing the law, will issue specific regulations in a few months.

Steiner criticized the lack of debate the amendment received in Congress and called the law "a mistake." The amendment is aimed primarily at elementary and secondary schools and is attached to the hotly debated education bill.

Harvard administrators last spring lobbied against similar legislation subsequently killed in the Massachusetts legislature.

Steiner said he foresees three principle problems resulting from the law. He said that student advising will be adversely affected by a lack of candid comments in student files.

Second, he cited the widespread worry that letters of recommendation may cease to be candid, thus losing their crucial role in college and graduate and professional school admissions and forcing schools to rely more heavily on objective criteria.

He also expressed concern that prospective employers may pressure students to release their complete records. Though Harvard's present policy on the oral release of information varies from office to office, a student's complete folder may never be released to an outside agency.

A "serious moral question" and a legal question is raised, Steiner said, by changing the rules of the game after recommendations have been written with a prior confidentiality agreement. Admissions files have in the past been designated confidential with the written agreement of the applicant. And whether such past agreements may be sustained under the new law remains unanswered.

Dean Whitlock said last week that the same question extends to other letters on file which were solicited by students with an agreement of confidentiality.

Several offices which will be affected by the legislation expressed uncertainty last week about the ramifications of the measure. L. Fred Jewett '57, dean of admissions and financial aid, said that his office is "just not sure what it means."