The unsettling news about MF Global's "missing" futures customers' funds has had one universal reaction: futures trading is risky enough; but if my account balances can disappear, I am out of here.

First, the irony. This about as rare as a winning lottery ticket. Never seen anything quite like it over my 50 years inside. The record, until now, has been pristine. The intensity of the reaction validates the phrase "No good deed goes unpunished.

Still, the new challenge facing the futures community is to restore customer confidence without imposing huge cost on the law abiding futures community.

Some pundits have argued in favor of a new insurance-type program to pay victims if the risk recurs. But the "risk premium" for such coverage - if private policies now offered are any indication - appear to be very large. And there is the "moral hazard" that a third-party indemnification scheme might encourage the ethically challenged to follow their instincts.

Many futures users have the alternative of the swaps market that, by some measures, dwarfs futures volumes. A flight from futures as a result of MF-type uncertainty is a distinct possibility made even more likely if an expensive insurance overlay raises users' transaction costs. The FCM community must know this.

So, here is my proposal. Eliminate the risk. Require that, while the brokers will retain their relationships with customers (making recommendations and executing trades, sending trade confirmations and monthly statements, seeking to broaden customer relationships into securities and other investment media, etc.), have all customer funds go directly from and to customers through a CFTC-regulated central customer funds repository. All margins, all gains and losses, all distributions to closed accounts with occur from customer to repository and back.

Because the FCMs earn important income from the investment of customer funds, I would allow the repository to share its own investment results with the FCMs, or with the customers where the FCM and the client so negotiate.

This elimination of the troublesome risk (avoiding the cost of insurance), coupled with commissions, fees and investment income should reduce any impact on FCM profitability.

And my model would be a new business opportunity for existing clearinghouses. After all, the back office of the repository will look a lot like the work of clearinghouse managers. Is there an affiliate in their future?

This idea has been shared with key industry decision makers. It deserved a full vetting. And, wouldn't it be nice to tell worried customers: Oh, that? It has been fixed. It can't happen again."