Washington-area banks have among the highest fees in the nation for bounced or bad checks and for miscellaneous monthly checking account charges to customers with low-balance accounts, the Consumer Federation of America (CFA) said yesterday.

"There's been a shift in the burden of the cost of banking. ... Low- and moderate-income consumers are the ones who have been most severly impacted," said Ken McEldowney, executive director of Consumer Action, a consumer advocacy organization in San Francisco that cosponsored the survey released yesterday.

In the District, the average cost of a non-interest-bearing checking account that requires a minimum balance was $127.07 in 1990. For banks in Maryland, the cost was $134.95. Virginia banks charged $123.29.

The national average for non-interest-bearing checking accounts was $107.96, the survey said.

Similarly, the average fee for a bounced check in the District is about $22 compared with a national average of $15. Maryland banks topped the survey for bounced check fees, charging an average of $23.

For attempting to deposit a bad check, District banks charge an average of $9, close to double the national average.

"The fees are so high that they more than offset any interest gained on a relatively small account," McEldowney said.

Nationwide, the survey found bank fees for low-balance accounts continued on an upward spiral that began when banks were deregulated a decade ago. Since 1983, when the CFA conducted its first bank fee survey, such charges have increased 62.3 percent for interest-bearing checking accounts and 28 percent for non-interest bearing checking accounts.

McEldowney attributed the rise in banking fees to deregulation, a lack of competition among banks on the fees they charge and an industry practice of using income from fees to subsidize high-interest-rate certificate of deposits.

The CFA estimate on how fees have increased was based on a typical low-balance account with an average monthly balance of $400 and a minimum balance of $200. The "customer" wrote 10 checks a month, withdrew funds from an automatic teller machine four times a month, bounced two checks and attempted to deposit one bad check a year.

CFA conducted the survey of 170 banks in 15 states and the District over a two-week period last March. The survey examined interest and non-interest-bearing checking accounts and money market deposit accounts.

It did not look at so-called basic checking accounts that do not require a minimum balance and allow a limited number of checks to be written without a fee.

The American Bankers Association, speaking for the banking industry, criticized the exclusion of basic checking accounts from the survey and denounced the survey's methodology.

"In many cases, regular accounts {with a minimum deposit} may not be for everyone," said Virginia C. Stafford, an ABA spokeswoman , who said that a recent ABA survey found that 59 percent of all banks offer basic accounts. "The CFA survey in no way can be generalized to the rest of the industry."

Stafford said bank fees have remained at stable levels, with "a small increase in {fees charged by} small banks."