Andrea is a member in the firm’s Real Estate Practice Group as well as a member of the Hemp Industry Team, focusing her practice on both affordable housing and cannabis business law. In the affordable housing area, Andrea represents both for-profit and non-profit developers across the country, including public and private entities, as well as public housing authorities and tax increment reinvestment zones. Her work is concentrated on the legal representation of developers of affordable housing utilizing both 9% and 4% Low Income Housing Tax Credits, tax exempt bond financing, CDBG and HOME Program funding and other federal, state and local subsidy and economic development programs, as well as the stimulus grants created by the American Recovery and Reinvestment Act of 2009 including the Tax Credit Assistance Program, Tax Credit Exchange Program (Section 1602 Program) and the Neighborhood Stabilization Program.
Andrea has represented developers in complex transactions which have combined federal and state Historic Tax Credits with LIHTCs and tax-exempt bonds, and transactions which have involved multiple layers of funding including EB-5 and tax increment financing. Her practice also includes closing construction, bridge and/or permanent loans, conventional as well as Freddie Mac/Fannie Mae loans, FHA-insured loans, and state and local financing. Incorporating various economic development incentives is another area in which her creativity and experience allows her to excel.
Andrea’s work with public housing authorities (PHAs) includes closing transactions that include HUD funds and/or HUD-insured mortgages, including Rental Assistance Demonstration (RAD) and mixed-finance transactions, those involving Section 8 financing, 221(d)(4) & 223(f) FHA mortgages, Federal Home Loan Bank AHP loans and CDBG Disaster Recovery funds. She has worked with PHAs throughout Texas in addition to Louisiana, Arkansas, and the U.S. Virgin Islands.
Andrea is also experienced with assisting developers navigate through various state agency processes, including assistance with funding applications, appeals, and compliance issues. Her work also encompasses obtaining ad valorem tax exemptions for qualified projects, and she also assists clients with real estate acquisitions and dispositions.
In addition to real estate, Andrea has deep rooted knowledge and experience with cannabis law. Andrea’s cannabis business clients come from across the supply chain spectrum from cultivators to retailers, as well as distributors, testing labs and more. She advises on regulatory compliance, hemp/medical marijuana licensing, cannabis-related business issues, product labeling/marketing, policy-making participation and real estate issues.
Andrea frequently advises clients on issues unique to the industry, such as delta-8 and other novel cannabinoids, conducting state-by-state research and providing guidance and analysis on proposed laws to policymakers and others. She serves as co-chair of the Legislative Advisement Committee of the International Cannabis Bar Association and has been appointed as Vice Chair of the American Bar Association’s Cannabis Law and Policy Committee for the 2021-22 year. She is also a sought-after speaker at industry events, providing insight into recently approved and proposed laws, rules and regulations and other cannabis business matters. At her prior firm, she successfully launched, led and grew their cannabis business practice group.
With both affordable housing and cannabis being industries that necessitate guidance across a wide range of practice areas, Andrea enjoys collaborating with other team members at Frost Brown Todd to provide clients a full suite of legal services on any issue impacting their businesses, including trademarks, patents, e-commerce, tax matters, debt and equity financing opportunities, corporate structuring and more.
Prior to joining Frost Brown Todd, Andrea spent 12 years at a regional firm in their Affordable Housing Group, where she also created and chaired their Cannabis Business Law Group. While earning her law degree, Andrea she served as an intern for Justice John S. Anderson of the 14th Court of Appeals, an extern for the Center for Children, Law, and Policy, and participated in the Law Center’s Civil Practice Clinic. Prior to becoming an attorney, Andrea worked in the criminal justice field, where she supervised halfway house residents in Maryland and served as a parole and probation officer in both Washington, D.C. and Harris County, Texas.
University of Maryland, B.A., Criminal Justice and Sociology, 2002
Texas, 2010
Oklahoma, 2020
State Bar of Texas
American Bar Association, Member (Forum on Affordable Housing and Community
American Bar Association, Vice-Chair of the Cannabis Law and Policy General Committee 2021-2022
Houston Bar Association
Texas Association of Affordable Housing Providers
NORML Legal Committee
International Cannabis Bar Association, Co-Chair of the Legislative Advisement Committee
Minorities for Medical Marijuana
Delta Sigma Theta Sorority, Inc.
Podcast Guest, Episode #80, The Texas Hemp Show, May 12, 2022
Panelist, “Panel Room: Sustaining a Business in Today’s Volatile Cannabinoid Industry,” Delta 8 Expo, April 1, 2022
Panelist, “Center Stage: The Great Delta 8 Debate,” Delta 8 Expo, March 30, 2022
Panelist, “Careers in Cannabis,” Texas Cannabis Policy Conference, March 5, 2022
Podcast Guest, “Novel Cannabinoids,” Hemp, Legally Speaking, September 27, 2021
Speaker, Topics: Smokable hemp ban, DSHS changing the definition of THC for the state of Texas, Podcast: Lonestar Collective – Episode 5. September 7, 2021
Moderator, “Emerging Markets: Adult-Use – The Newest States Taking it to a Higher Level,” May 10, 2021
Panelist, “What can Texas learn from other states?” Texas Marijuana Policy Conference, November 20, 2020
Presenter, “Update on Hemp & Cannabis Laws,” Houston Academy of Cannabis Science, November 14, 2020
Panelist, “USDA Versus State Rules,” 2020 Cannabis Law Institute, International Cannabis Bar Association, October 20, 2020
Presenter, “Industrial and Medicinal Hemp,” EarthX Young Professional (YPX), September 30, 2020
Presenter, “Legal, FDA, USDA Regulatory Update,” CBD Training Academy – Success Webinar, March 11, 2020
Panelist, “Expert Live Q & A,” to Texas Hemp Growers, Big Spring, Texas, March 7, 2020
Presenter, “Hemp Laws in Texas,” Texas Hemp Federation Industry Stakeholder Meeting, Austin, Texas, February 13, 2020
Panelist, “Expert Live Q & A,” to Texas Hemp Growers, San Antonio, Texas, February 8, 2020
Panelist, “Ask the Experts: Myth-Busting Legal & Practical Misconceptions About the Hemp Industry,” Texas Hemp Convention 2020, Dallas, TX, January 30, 2020
Panelist, “Expert Live Q & A,” Texas Hemp Growers, Bryan/College Station, Texas, January 25, 2020
Panelist, “Expert Live Q & A,” to Texas Hemp Growers, Dallas, Texas, December 7, 2020
Co-author, “No Roof for Your Reefer! Medical Cannabis Tenants Need Patient Protections in Federally Assisted Housing,” TortSource, American Bar Association, May 11, 2022
Co-author, “The Medical Cannabis Program Rules for The State of Texas are Open for Public Comment,” New Cannabis Ventures, April 25, 2022
Quoted, “Texas Judge Temporarily Blocks State’s Delta-8 Ban,” Law360, November 9, 2021
Quoted, “Judge grants temporary injunction in Texas delta-8 case” Texas Cannabis Collective, November 8, 2021
Quoted, “Texas’ Delta 8 ban faces new legal challenge from Houston vape shop,” Chron, October 26, 2021
Quoted, “First Shots Fired in Texas Delta-8 THC Legal Battle,” Hemp Gazette, October 26, 2021
Quoted, “Delta-8 case TRO denied by district Judge,” Texas Cannabis Collective, October 25, 2021
Quoted, “Texas hemp retailer sues state health department after delta-8 THC status change,” Hemp Industry Daily, October 22, 2021
Quoted, “Texas co. seeks temporary restraining order against Texas DSHS for Delta-8-THC clampdown,” Houston Business Journal, October 22, 2021
Author, “Dear 87th Legislative Session – What Happened Y’all?” Texas Hemp Reporter, July 2021
Author, “Debt Forgiveness for Farmers of Color,” TexasCannaBizLaw Blog, March 2021
Quoted, “This Drug Gets You High, and Is Legal (Maybe) Across the Country,” New York Times, February 27, 2021
Quoted, “Some Pa. stores sell Delta-8 THC, which promises a weed-like high. Is it legal?” York Daily Record, February 24, 2021
Quoted, “Your Guide to the USDA’s Final Rule on Hemp,” Hemp Grower, January 20, 2021
Podcast, “Cannabis Legal Low Down with Andrea Steel, Esq.,” Dr. Carlie, 2020
Quoted, “Cannabis Attorneys Push USDA to Fix Hemp Rule,” Law360, October 9, 2020
Co-author, “Did the DEA’s new rule confirm hemp-derived Delta-8 THC is illegal?” Cannabis Business Executive, Blog, October 2020
Quoted, “Hemp farmers get last-minute delay on USDA compliance, but not everyone is happy,” Hemp Industry Daily, October 2, 2020
Co-author, “Smokable Hemp Ban in Texas, Temporary Injunction Granted – Win for Texas Manufacturers, Processors & Retailers,” September 17, 2020
Quoted, “Hemp industry worries DEA rule puts extractors at risk, but path forward unclear,” Hemp Industry Daily, September 8, 2020
Co-author, “Did the DEA’s new rule confirm hemp-derived Delta-8 THC is illegal?” Cannabis Business Executive, September 1, 2020
Quoted, “Criticized retail smokable hemp ban becomes official, and it’s stricter,” Texas Cannabis Collective, July 20, 2020
Author, “Clock Ticking on Two USDA Opportunities for Hemp Growers,” Hemp Industry Daily, July 15, 2020
Author, “Texas Medical Marijuana: “Incurable Neurodegenerative Disease,” TexasCannaBizLaw Blog, October 18, 2019
Author, “TX Health Dept. Holds Public Hearing on Consumable Hemp Products,” TexasCannaBizLaw Blog, October 4, 2019
Author, “How to Get a Medical Marijuana Dispensary License in Texas,” TexasCannaBizLaw Blog, September 26, 2019
Quoted, “Delta-8 legal for now, appeals court holds up Hometown Hero side of injunction,” Texas Cannabis Collective, November 18, 2021
May 12, 2022
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