The banking industry yesterday gave the government a $12 billion plan for propping up the flagging Federal Deposit Insurance Corp., but there were immediate warnings that the plan drafted by five banking trade associations may not be enough to keep the FDIC healthy.

The proposal calls for the nation's banks to lend the FDIC $10 billion to pay for the cost of bank failures over the next couple of years. It also asks the Federal Reserve Board to kick in $2 billion to be used to prevent bank failures.

Neither the Fed, the FDIC nor the Treasury Department would comment on the proposal, which is intended to head off the need for the taxpayers to bail out the FDIC. But a number of officials pointed out that the $10 billion figure is at the low end of current estimates of how much additional money will be needed to keep the bank insurance fund afloat.

House Banking Committee Chairman Henry B. Gonzalez (D-Tex.) was among those yesterday who questioned whether the bankers' plan would provide sufficient funds. He also criticized the decision of the administration to leave the job of fixing the FDIC up to the banking industry.

"The administration -- not the banking lobbyists -- needs to submit the details of any plan for bailing out the bank insurance fund," said Gonzalez. He called the industry proposal a "public relations smoke screen designed to hide the fact that banks may soon be at the federal welfare window."

The bankers say their goal is to ensure that the FDIC will not require the same kind of taxpayer support as the savings and loan insurance fund, which is now projected to cost the taxpayers as much as $500 billion, including interest, over the next 20 years.

Richard Kirk, president of the American Bankers Association, said pumping $10 billion into the FDIC "will meet the immediate needs of the insurance fund" based on projections that the recession will be over within a few months.

Kirk said the trade association officials who developed the plan over the past two weeks have not decided what to do if the FDIC turns out to need more than $10 billion.

In addition to the ABA -- the largest bank trade association -- the plan was endorsed by the Independent Bankers Association of America, which represents small-town banks, and three smaller groups: the Association of Bank Holding Companies, the Association of Reserve City Bankers and the Consumer Bankers Association.

The bankers acknowledge they are facing much the same situation that the S&L industry was up against five years ago: Failures are rapidly eroding the deposit insurance fund and the industry cannot afford to replenish the fund simply by paying higher premiums.

As part of their plan, the bankers want the FDIC to freeze deposit insurance premiums at the present level, a move the FDIC and the Treasury are likely to resist.

The bankers also want the Treasury or the Fed to start picking up the costs of rescuing banks that are considered "too big to fail" because their collapse would threaten the banking system. Deposit insurance was meant to protect small depositors, not big banks, they argue, and the FDIC should not be used to pay for banks that are rescued for political or economic reasons.

That plan was attacked yesterday by the National Council of Savings Institutions, which represents a large number of FDIC-insured savings banks. "The problem the banking industry faces is the too-big-to-fail doctrine itself. Developing a plan to pay for 'too-big-to-fail' doesn't solve the fundamental problem," said Martin Regalia, the council's senior vice president for economics and research.