Joseph James Adamo (CRD #2016233, Registered Principal, Rocky River, Ohio) submitted a Letter of Acceptance, Waiver and Consent in which he was barred from association with any NASD member in any capacity. Without admitting or denying the findings, Adamo consented to the described sanction and to the entry of findings that he caused customer funds to be diverted from his member firm’s third-party administrator non-ERISA 403(b) account to other bank accounts his member firm and subsidiaries owned to pay for their operating expenses, and then transferred the funds back into the account to purchase insurance and securities products for firm customers. The findings stated that Adamo signed checks from the account to his member firm and its affiliates, but had concerns that customer money was being used inappropriately only when it appeared that money was not being returned to the account. The findings also stated that Adamo’s response to an NASD Letter of Caution was false and misleading, in that he made it appear that his reporting relationship to an individual at his firm would not require the individual to be registered as a financial and operations principal (FINOP), when, in fact, it was required since he supervised Adamo. (NASD Case #E8A2004101502)