Banks and thrifts have found plenty to gripe about in Congress' plan to rebuild the Savings Association Insurance Fund.

But at least one part of the proposal seemed settled months ago - a provision requiring thrifts to pay a one-time special assessment on deposits held on March 31, 1995.

Now regulators and the thrift industry are having second thoughts.

That assessment date could be more than a year old by the time the bailout is enacted. By then, more than 100 thrifts will have been merged out of existence, according to FDIC estimates. That removes as much as $50 billion in deposits from the assessment base, increasing the burden for those who are still around to pay the $6 billion needed to replenish the thrift fund.

With those sobering facts in hand, America's Community Bankers, the thrift trade group, sounded the alarm last week.

The tab for the remaining thrifts could rise by $400 million once that $50 billion is cut from the assessment base, wrote Paul A. Schosberg, the trade group's president, in letters to the chairmen of the House and Senate banking committees.

According to FDIC officials, institutions won't pay an assessment on any thrift deposits acquired after March 31.

That provision is a boon to some of the biggest banks in the country, including First Union Corp. and NationsBank Corp., which have acquired thrifts in the past nine months.

Charlotte, N.C.-based First Union would save $74 million from its acquisition of seven thrifts in the past nine months, while NationsBank would save $27 million on deposits from its purchase of Miami-based Citizens Federal Savings Bank.

Others reaping the harvest include Richmond, Va.-based Crestar Financial Corp., Fifth Third Bancorp, First Nationwide of Texas, First American of Tennessee, and Charter One of Ohio.

But the windfalls at those institutions force most thrifts to "subsidize a nine-month acquisition binge conducted by others," Mr. Schosberg said.

The trade group wants the assessment moved to a later date, preferably Dec. 31. But its efforts may be futile.

The package is part of the balanced budget plan now being debated by Congress and the Clinton administration. The banking portions of the bill are among the few topics on which the lawmakers and the President agree. Neither side is eager to reopen the banking issues.

House Banking Committee aides acknowledged that the March 31 date rips a hole in the assessment base. But they say the assessment is not likely to be different from the range of 81 to 85 cents per $100 of deposits that was projected last spring. As a result, the House will have little incentive to make a change.

Senate Banking staffers said Thursday they were reviewing trade group's complaint and would not comment.

Bank lobbyists complain that in the rush to create the bailout plan, Congress did not consider the impact of a delay in the rescue's enactment.

"The passage of time revealed a problem that was not thought about very carefully," said Bert Ely, an Alexandria, Va.-based banking consultant.

When Congress began debating the thrift bailout plan, March 31 was the most recent date for which deposit data were available, said a House Banking Committee staffer.

Some thrifts will be doubly hurt by the March 31 assessment. Household International will bear the extra burden and will be assessed for $4 billion in deposits it sold in the past nine months. "We're going to pay on deposits we don't have. It's a pretty outrageous situation," said J. Denis O'Toole, Household's Washington lobbyist.

A few thrifts, however, will benefit. Since March 31, roughly $4 billion in savings association deposits have been acquired by other thrifts.

"This is not a banks versus thrifts issue," said Mr. O'Toole.

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