Mary Schapiro's planned departure from the Commodity Futures Trading Commission will leave the futures and options regulation agency with two of its five commission seats vacant for the second time in the last two years.

While the Clinton administration searches for possible replacments - a process that may stretch past election day 1996 - some observers are worried that it may be difficult for the agency to respond as decisively as it did to the Barings PLC collapse should another crisis arise in the futures market.

On Dec. 4, Ms. Schapiro announced that she would resign as chairwoman of the futures agency effective Jan. 26. She is leaving to become head of the National Association of Securities Dealers' new regulatory arm.

With trading losses high in the public consciousness, the departure of Ms. Schapiro comes at an inopportune time.

The Barings Brothers collapse was the only billion-dollar financial disaster to involve trading in futures contracts. But some observers credit the agency, under Ms. Schapiro's leadership, with isolating the losses and preventing a market meltdown.

"Al Greenspan and Arthur Levitt were getting a good night's sleep knowing that it was Mary Schapiro who was rousing regulators from around the world" at the time of the Barings collapse, said John Damgard, president of the Futures Industry Association.

"If we had our way, we'd keep her here for life."

After Ms. Schapiro leaves, the agency will be left with three commissioners.

Finding someone to fill her role will be difficult, said W. Robert Felker, president of First Chicago Futures.

Her resignation "came as a quite a surprise to many people in the industry," he said.

Speculation has focused on three current government officials.

Of those, Douglas E. Harris, senior deputy Comptroller of the Currency for capital markets, is the best known.

Prior to joining the Comptroller, he headed J.P. Morgan's futures operations and has worked with the commodity regulator in recent months in developing bank examiner guidelines for banks' futures commission merchants.

Through a spokeswoman at the Comptroller's office, Mr. Harris refused to comment.

Also seen as possible replacements are current Securities and Exchange commissioner Steve Wallman and Department of Agriculture general counsel Jim Gilliland.

Any nominee will face approval by the House and Senate agricultural committees before taking office.

And some speculate that approval of a chairman could hinge on approval of Dave Spears to fill the remaining commission slot.

Mr. Spears is an aide to Sen. Bob Dole, and the Kansas senator is said to be pushing for his appointment.

The current commission is comprised of two Clinton appointees and one Bush appointee.

The Clinton appointees are John Tull, an Arkansas farmer, and Barbara Pedersen Holum, a former president of the National Agriculture Lands Center. The Bush appointee is Joseph Dial, a Texas farmer.

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