THE special interests that oppose reform of the United State's creaking banking system evidently are, like some banks, too big to fail. So it appears from the fate of bank-reform legislation in Congress this year.America is in a banking crisis. Banks continue to fail at the fastest rate since the Great Depression, dragged down by plummeting real estate portfolios. The nation's deposit-insurance fund, with just $2 billion left, is expected to be empty within a few months if it doesn't get a new infusion of cash. Few experts anticipate a banking debacle and resulting government bailout on the scale of the savings-and-loan disaster; but in virtually every state, disruptions in the banking system and in the financial affairs of bank customers are likely to increase. Acknowledging the crisis, Congress nonetheless has been ineffectual in stemming it. In February President Bush proposed legislation to replenish the deposit-insurance fund and tighten regulatory oversight of the banking system; in addition, banks would have been permitted to strengthen their financial base through interstate networks of branches, diversified lines of business, and access to capital from industrial corporations. Ten months later, however, the nation is still without a banking bill. Last week the House overwhelmingly rejected the bill placed before it, 324 to 89, and the vote made senators so gun-shy they backed off from considering the Senate version of the legislation. The vote was a victory of sorts for the administration and the major banks that support Bush's reforms. By the time the bill reached the House floor it had been turned topsy-turvy by supporters of the securities and insurance industries, which oppose administration plans to let banks enter their business preserves. In fact, though, the vote was a defeat for everyone, not least the American people. It leaves banking reform in gridlock - a condition that has become all too familiar in Washington's efforts to address major national problems. There is still time this year for Congress to enact a scaled-down version of the law. A bill subsequently approved by the House Banking Committee would provide additional funds to insure depositors in failed banks and would empower regulators to intervene more quickly when banks teeter. Though necessary, these measures are tire-patches. Comprehensive reform will likely be put aside until after the 1992 elections, at the earliest. Americans deserve much better from their political leaders on this critical issue.