It is probably inaccurate to say that an interstate banking measure approved by a D.C. City Council committee this week is a Christmas-tree bill, but there can be little argument that it contains something for all parties concerned.

The potential beneficiaries of the bill may not be enthusiastic about all of its provisions, but they could do worse.

Like the thousands of recipients of gifts that aren't quite right for them, however, some parties addressed in the bill probably will want to make some exchanges after Christmas.

In the meantime, it appears that the mayor, the council, local banks, regional banks, non-regional banks and D.C. residents got much of what they wanted. What remains to be seen is whether one of those groups thinks the committee was more generous to some than it should have been.

Some observers say the committee's approval of the bill is a victory for big money-center bank companies, especially New York's Citicorp, which lobbied vigorously for legislation that would permit entry into the District by banks from outside the region. The council passed a law in September permitting interstate mergers only among D.C. banks and those in an 11-state Southeast region. Mayor Marion Barry favored full interstate banking, which some of the changes in the new bill would accommodate.

"I think it is a victory for [money-center banks], but it is a victory for us, too," declared council member Charlene Drew Jarvis, chairman of the committee that approved the new bill. "Everybody is a winner," Jarvis continued. "The mayor is a winner because he got what he wanted. The council is a winner because it got some control [over the regulation of interstate banking in the District]. The city is a winner, and the underserved areas of the city are winners. I think it's an extraordinary victory for the economic recovery of the city."

Local bankers don't seem to be in the mood to celebrate now, however. "I would not say that any of the bankers are ecstatic about this bill in its entirety," complained Michael F. Ryan, president of the D.C. Bankers Association. "We knew this bill was coming, but I'm not enthusiastically endorsing this bill either as president of the bankers association or as president of [NS&T] bank."

Translation: D.C. bankers strongly object to a key provision in the new bill that would permit non-regional banks to open new banks in the District.

The bill would allow non-regional banks, like their regional counterparts, to enter the District through acquisitions only. But three years after passage of the law, non-regional banks could establish banking offices here without acquiring an existing institution.

That, according to local bankers, is a trigger to national interstate banking, the very thing that they had lobbied successfully to have eliminated from the current regional interstate banking law.

While District bankers may compare Jarvis' committee to the Grinch that stole Christmas, there is no trigger in the bill, Jarvis insists. The difference, she emphasized, is that, with a trigger, "You let non-regional banks come in without any requirements."

Under the bill approved Wednesday, regional and non-regional banks will have to pay a fairly substantial price for banking privileges in the District.

Among other things, they must sign commitments calling for them to provide between $50 million and $100 million in loans, special types of mortgage loans, job training and employment for at least 200 D.C. residents, all within three years after being licensed to bank in the District. In addition, money-center banks would be required to commit a fixed percentage of their assets to designated areas of the District. The same banks would be required to put up a $10 million irrevocable letter of credit and could be fined as much as $5 million if they failed to live up to commitments that would be incorporated in their community development plans.

A Citicorp official was quoted as saying the new bill is "very positive" for his company. At the same time, Willard C. Butcher, chairman of New York's Chase Manhattan Corp., who was in Maryland yesterday for a briefing on Chase's recent acquisitions in that state, said he supports a trigger concept for entry into the District. Butcher hasn't yet seen the District's new banking bill but left little doubt that he would have difficulty accepting the other key provisions.

"I would have to look at provisions requiring any specific investments," he replied.

Enter the lawyers. Those representing local banks are already at work on the new bill. Counsel for out-of-state banks can't be far behind.

Soon, the line of bankers hoping to exchange the new interstate banking bill for something that fits them better will form at the entrance to the D.C. Council chambers.