"I asked to see my files last month," one undergraduate said, "and there wasn't a single thing in them that I hadn't written myself or already seen."

What that undergraduate may not have realized is that the Registrar's office had only shown him one of his files. Last week the University acknowledged that it maintains two parallel sets of student records, one accessible to students, the other completely off-limits.

Students are allowed to see their own college applications and their transcripts. But teacher recommendations and guidance couselor reports are locked away separately in the Admissions Office.

Harvard initiated the dual record-keeping system as a response to the Buckley Amendment, a 1974 federal law which for the first time guaranteed students the right to view their own files and to challenge anything which they considered to be inaccurate within them.

Roger Levy, a legislative assistant to the sponsor of the bill, Sen. James L. Buckley (Con-R-N.Y.), said on Tuesday that it was "up for dispute" whether Harvard could legally deny students the right to view letters of recommendation.

Daniel Steiner '54, general counsel to the University, said that the denial of access was legal because Harvard itself did not use the files once the admissions process was complete. Steiner said that the files are stored for three years to comply with state anti-discrimination laws and are then destroyed.

Harvard routinely sends applicants a form which allows them to give up the right to view their letters of recommendation. But William R. Fitzsimmons '67, director of admissions, said last week that whether or not applicants sign the waiver, their chances of seeing their recommendations are the same: all students are denied access.

Harvard has never come under heavy federal pressure to implement the Buckley Amendment. David B. Matthews, Secretary of Health, Education and Welfare and no champion of the bill, has been sitting on departmental guidelines for its implementation for months, and President Ford reportedly plans to ask Congress to amend the law, easing its requirements for institutions of higher learning.