Andrew J. Davalla
Partner
Andrew is a partner in the firm’s Corporate Transactions & Securities and Investment Management practice groups. With more than 15 years of in-house industry experience, most recently as senior vice president and counsel for a global investment management firm, he has a keen understanding and appreciation of issues from the investment manager’s perspective.
Andrew has extensive experience in providing ongoing representation of and advice to open-end investment companies, exchange-traded funds (ETFs), interval funds and their independent directors/trustees. His experience also includes advising on the full range of securities and compliance issues related to fund development and structuring, investment management agreements, third-party service agreements, corporate governance, fund mergers and acquisitions involving investment advisers. Having served in the role of privacy officer, he also gained valuable experience with data privacy and information security issues.
Andrew is licensed to practice in Ohio and New York.
- "SEC Proposes Amendments to Money Market Fund Rules," Thompson Hine Investment Management Update, January 2022
- "FINRA Raises Stakes in 2022 for Firms Tolerating Bad Brokerage Disciplinary Histories," Thompson Hine Investment Management Update, January 2022
- "SEC Proposes Enhanced Proxy Voting Disclosures," Thompson Hine Investment Management Update, October 2021
- “SEC Division of Investment Management Releases Statement on Bitcoin Futures and Registered Funds,” Thompson Hine Investment Management Update, May 2021
- "SEC Announces 2021 Exam Priorities," Thompson Hine Investment Management Update, March 2021
- "SEC Modernizes Framework for Fund Valuation Practices," Thompson Hine Investment Management Update, December 2020
- "SEC Adopts New Fund Derivatives Rule," Thompson Hine Investment Management Update, December 2020
- “SEC Adopts New Rule for Fund of Funds Arrangements,” Thompson Hine Investment Management Update, October 2020
- “SEC Proposes Mutual Fund and ETF Disclosure Amendments,” Thompson Hine Investment Management Update, September 2020
- “SEC Adopts Amendments to Exemptive Application Procedures,” Thompson Hine Investment Management Update, July 2020
- “SEC Extends Relief for Virtual Meetings of Fund Boards,” Thompson Hine Investment Management Update, July 2020
- “SEC Announces LIBOR Examination Initiative,” Thompson Hine Investment Management Update, July 2020
- “Volcker Rule Changes Will Expand Banks’ Investment Abilities,” Thompson Hine Investment Management Update, July 2020
- “OCIE Private Fund Adviser Examinations Reveal Common Compliance Issues,” Thompson Hine Investment Management Update, June 2020
- “SEC Proposes Rule to Establish Framework for Fund Valuation Practices,” Thompson Hine Investment Management Update, May 2020
- "SEC Provides Guidance on Disclosures of Registered Investment Advisers Using Paycheck Protection Program Loans," Thompson Hine COVID-19 Update, May 2020
- “SEC Temporarily Exempts Open-End Funds from Some Short-Term Funding Requirements,” Thompson Hine COVID-19 Update, March 2020
- "SEC Issues Guidance for Registered Funds Facing Operational Challenges due to COVID-19," Thompson Hine COVID-19 Update, March 2020
- “SEC Provides Temporary Regulatory Relief for Investment Advisers,” Thompson Hine COVID-19 Update, March 2020
- “SEC Issues Annual Meeting Guidance Amid COVID-19 Concerns,” Thompson Hine COVID-19 Update, March 2020
- “SEC Extends Relief Overriding In-Person Meeting Requirements,” Thompson Hine Investment Management Update, March 2020
- "SEC Seeks Comment on Amending 'Names Rule' to Eliminate Misleading Fund Names," Investment Management Update, March 2020
- "SEC Extends Relief Overriding In-Person Board Meeting Requirements," COVID-19 Update, March 2020
- “SEC Proposes Rules Governing Use of Derivatives,” Thompson Hine Investment Management Update, January 2020
- “OCIE Announces 2020 Examination Priorities,” Thompson Hine Investment Management Update, January 2020
- "SEC Proposes Revisions to the Advertising Rules for Investment Advisers," Thompson Hine Investment Management Update, December 2019
- “The ETF Evolution Continues: SEC Approves Four New “Proxy Basket” Active Semi-Transparent ETFs,” Thompson Hine ETF Reg Insights, December 2019
- "ETF Complexes Should Prepare Now to Comply with New Rule 6c-11 to be in a Position to Unlock Its Key Regulatory Advantages by Year-End," Thompson Hine ETF Reg Insights, October 2019
- “Advisory Firm Fined $15 Million for Improper Fees on Inactive Accounts and Failure to Disclose Conflict of Interest,” Thompson Hine Investment Management Update, September 2019
- “SEC Issues New Guidance Regarding Investment Advisers’ Proxy Voting Responsibilities and Proxy Advisory Firms,” Thompson Hine Investment Management Update, September 2019
- “SEC Issues No-Action Letter Regarding Fund Board In-Person Voting Requirements,” Thompson Hine Investment Management Update, March 2019
- “FINRA Guidance Permits Pre-Inception Index Performance Data in Fund Communications with Institutional Investors,” Thompson Hine Investment Management Update, February 2019
- “SEC Proposes New Rule for Fund of Funds Arrangements,” Thompson Hine Investment Management Update, January 2019
- “NFA Proposes Amendments to 2016 Cybersecurity Guidance,” Thompson Hine Investment Management Update, December 2018
- “SEC Adopts Safe Harbor Rule for Investment Fund Research Reports,” Thompson Hine Investment Management Update, December 2018
- “Ohio Elder Abuse Mandatory Reporting Requirements for Financial Services Professionals,” Thompson Hine Investment Management Update, December 2018
- “SEC Issues No-Action Letter Allowing Fund Boards to Rely on CCO Representations to Comply with Certain Exemptive Rules,” Thompson Hine Investment Management Update, October 2018
- “SEC Issues Risk Alert on Best Execution Practices,” Thompson Hine Investment Management Update, July 2018
- “Further Staff Guidance on Inadvertent Custody,” Thompson Hine Investment Management Update, July 2018
- “SEC Suspends Pending Administrative Proceedings in Wake of Lucia Decision,” Thompson Hine Investment Management Update, July 2018
- “SEC Allows Temporary Mutual Fund Redemption Delays When Financial Exploitation of Seniors Is Suspected,” Thompson Hine Investment Management Update, June 2018
- “SEC Charges 13 Private Fund Advisers for Failures to File Form PF,” Thompson Hine Investment Management Update, June 2018
- “SEC Proposals Promote Distribution of Research on Investment Funds,” Thompson Hine Investment Management Update, June 2018
- “SEC Proposes Changes to Auditor Independence,” Thompson Hine Investment Management Update, June 2018
- “OCIE Issues Risk Alert Regarding Advisory Fee Violations,” Thompson Hine Investment Management Update, April 2018
- Quoted, "Liquidity Rule's Buckets Could Still Get Dumped: Sources," Ignites, April 2018
- “SEC Proposes Changes to Liquidity Risk Disclosures,” Thompson Hine Investment Management Update, March 2018
- “OCIE Announces 2018 Examination Priorities,” Thompson Hine Investment Management Update, March 2018
- “Most Common Advertising Rule Compliance Issues Raised in OCIE Deficiency Letters,” Thompson Hine Investment Management Update, October 2017
- “Advisers Must Offer Investors the Lowest-Fee Share Class Available,” Thompson Hine Investment Management Update, September 2017
- “Fund of Funds Investor Loses Appeal on Excessive Fee Case,” Thompson Hine Investment Management Update, August 2017
- “Supreme Court Ruling Limits SEC Disgorgement Recoveries,” Thompson Hine Investment Management Update, June 2017
- “Federal Court Upholds Attorney-Client Privilege in Discovery Dispute,” Thompson Hine Investment Management Update, May 2017
- “SEC Issues Guidance on Robo-Advisers,” Thompson Hine Investment Management Update, March 2017
- “OCIE Identifies Five Most Common Adviser Compliance Deficiencies,” Thompson Hine Investment Management Update, February 2017
- “SEC Issues Guidance on Section 22(d) Restrictions,” Thompson Hine Investment Management Update, February 2017
- “SEC Guidance for Funds Offering Sales Load Variations and New Share Classes,” Thompson Hine Investment Management Update, January 2017
- “Federal Court Permits Fiduciary Exception to Attorney-Client Privilege,” Thompson Hine Investment Management Update, December 2016
- “SEC Approves FINRA Rule Amendments Governing Mutual Fund Retail Communications,” Thompson Hine Investment Management Update, November 2016
- “Investment Company Reporting Modernization,” Thompson Hine Investment Management Update, November 2016
- “SEC Adopts Rule Requiring Liquidity Risk Management Programs for Funds,” Thompson Hine Investment Management Update, October 2016
- “SEC Issues No-Action Letter on Fund Auditor Independence,” Thompson Hine Investment Management Update, August 2016
- “SEC Proposes Business Continuity & Transition Plan Rule,” Thompson Hine Investment Management Update, July 2016
- “SEC Issues No-Action Relief to ETF Seeking to Exceed Insurance Company Investment Limits,” Thompson Hine Investment Management Update, May 2016
- “FINRA Issues Report on Digital Investment Advice,” Thompson Hine Investment Management Update, April 2016
- “Advisers Fined for Steering Clients to Higher-Fee Funds,” Thompson Hine Investment Management Update, March 2016
- “Funds Must Disclose Risks Related to Current Market Conditions,” Thompson Hine Investment Management Update, March 2016
- “FINRA Proposes Revised Broker-Dealer Pay-to-Play Rules,” Thompson Hine Investment Management Update, March 2016
- “2016 FINRA Exam Priorities,” Thompson Hine Investment Management Update, January 2016
- “SEC Proposes Derivative Rules for Registered Investment Companies,” Thompson Hine Investment Management Update, December 2015
- “Do’s & Don’ts for Advisers & Funds With Outsourced CCOs,” Thompson Hine Investment Management Update, December 2015
- “New AML Regulations Proposed for Certain Investment Advisers,” Thompson Hine Investment Management Update, October 2015
- “SEC Proposes Fund Liquidity Risk Management Programs,” Thompson Hine Investment Management Update, October 2015
- “Money Market Fund Rule Amendments,” Thompson Hine Investment Management Update, September 2015
- “OCIE Names Focus Areas for 2015 Cybersecurity Examinations,” Thompson Hine Investment Management Update, September 2015
- “SEC Brings First Enforcement Action Under Distribution-in-Guise Initiative,” Thompson Hine Investment Management Update, September 2015
- “Second Circuit Broadens Dodd-Frank Whistleblower Interpretation,” Thompson Hine Investment Management Update, September 2015
- “SEC Brings Charges Related to 15(c) Process Failures,” Thompson Hine Investment Management Update, June 2015
- “SEC Proposes New Reporting Rules,” Thompson Hine Investment Management Update, June 2015
- “SEC Proposes Changes to Form ADV & Recordkeeping Requirements,” Thompson Hine Investment Management Update, June 2015
- “FINRA Proposes Changes to Retail Communications Rules,” Thompson Hine Investment Management Update, June 2015
- “SEC Enforcement Action Highlights Profitability Analysis in 15(c) Process.” Thompson Hine Investment Management Update, May 2015
- “Confidentiality Agreements Have “Chilling” Effect on Would-Be Whistleblowers,” Thompson Hine Investment Management Update, April 2015
- “SEC Grants Orders to Include In-Laws in Family Office Exemption,” Thompson Hine Investment Management Update, March 2015
- “SEC Chair Addresses Risks & Regulatory Safeguards for the Asset Management Industry,” Thompson Hine Investment Management Update, December 2014
- “SEC Guidance on Consolidating Investment Company Financial Statements,” Thompson Hine Investment Management Update, November 2014
- “SEC Takes Action Against Corporate Insiders for Disclosure Violations,” Thompson Hine Investment Management Update, September 2014
- “Investment Adviser Proxy Voting Responsibilities & Use of Proxy Advisory Firms,” Thompson Hine Investment Management Update, July 2014
- “SEC Issues Guidance on Mutual Fund Summary Prospectuses,” Thompson Hine Investment Management Update, July 2014
- Presenter, "Non-compete Agreements: What You Need to Know," Thompson Hine Investment Management Coffee Chat webinar series, June 30, 2021
- Presenter, "R.I.P. ESG? Implications of Recent ERISA Guidance on ESG Investing," Thompson Hine Investment Management Coffee Chat webinar series, March 24, 2021
- "The DOL's Final Fiduciary Rule – What It Means To Your Business," August 23, 2017
- Listed in Legal 500, 2018 to 2021
New York State Bar Association
IM Coffee Chat – 2022 Compliance Priorities and Predictions
February 16, 2022