Andrea is a Director at Coats Rose and she also co-leads the Firm’s Cannabis Business Law group. She also serves as a Director in the Affordable Housing and Community Development section of the Firm.
Andrea’s role as head of the Cannabis Business Law group began taking shape many years ago when she initially became intrigued by the willingness of some states to authorize medical marijuana programs in clear conflict with federal law. Already fascinated by the increasing number of states following suit, she became even more rivetted when some states began legalizing adult-use, and she started following the fast-changing legal business landscape more closely. In 2015, Texas authorized a limited medical marijuana program which was then expanded by the State Legislature in 2019. The 2018 Farm Bill was then passed in December 2018, providing a carveout for industrial hemp from the Federal Controlled Substances Act. Having been diligently following the changing laws, when HB1325 was passed by the Texas Legislature in June 2019 authorizing the production of hemp in Texas after a substantial hiatus due to prohibition, she became engrossed in the subject area and led the effort to bring together a team of attorneys at the Firm able to provide legal services to individuals and companies starting or expanding their legal cannabis businesses in Texas.
Andrea’s cannabis business clients come from across the supply chain spectrum from cultivators to retailers, where she advises on regulatory compliance, hemp/medical marijuana licensing, cannabis-related business issues, product labeling/marketing, policy-making participation and real estate issues. She also speaks at events across the state providing insight into the recently approved and proposed laws, rules and regulations and other cannabis business matters.
Andrea began her legal career at Coats Rose while still a law student, clerking at the Firm during the summer before her final year in law school. Captivated by the opportunity to work in business law while simultaneously serving the community, she was drawn to the affordable housing industry and spent the majority of her time working for that section, eventually earning clerkship extensions which lasted through her final semester. Following her graduation from law school, Andrea remained in the Firm’s affordable housing group, where she has now spent more than a decade serving the industry as an advocate for her clients, closing countless transactions resulting in thousands of housing units for families and individuals with limited incomes.
As an affordable housing attorney, she 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 (TIRZs). Her work is concentrated on the legal representation of developers of affordable housing utilizing both 9% and 4% Low Income Housing Tax Credits (LIHTCs), 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 (ARRA) including the Tax Credit Assistance Program (TCAP), Tax Credit Exchange Program (Section 1602 Program) and the Neighborhood Stabilization Program (NSP).
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 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.
She 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.
Andrea joined Coats Rose in 2010 after clerking with the firm since 2009. She received her Juris Doctorate, cum laude, from the University of Houston Law Center in 2009 and graduated from the University of Maryland, College Park, with a double-major Bachelor of Arts in Criminal Justice and Sociology in 2002. During her time at the University of Houston Law Center, she served as an Articles Editor for the Houston Business & Tax Law Journal and was a recipient of the Lex Award for Scholastic Excellence in Practice Skills. Andrea’s academic achievement also earned her a membership in the Order of the Barons Scholastic Honor Society.
While earning her law degree, 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’s professional experience was 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.
- Oklahoma, 2020
- Texas, 2010
- J.D., cum laude, 2009, University of Houston Law Center
- B.A., 2002, University of Maryland, Criminal Justice and Sociology
- State Bar of Texas
- American Bar Association (Forum on Affordable Housing and Community Development Law)
- Houston Bar Association
- Texas Association of Affordable Housing Providers
- NORML Legal Committee
- International Cannabis Bar Association
- Minorities for Medical Marijuana
- Delta Sigma Theta Sorority, Inc.
- “What can Texas learn from other states?” Texas Marijuana Policy Conference, A. Steel, panelist, virtual conference, November 20, 2020
- “Update on Hemp & Cannabis Laws,” presented to Houston Academy of Cannabis Science, November 14, 2020
- “USDA Versus State Rules,” 2020 Cannabis Law Institute, A. Steel, panelist, International Cannabis Bar Association, October 20, 2020
- “Industrial and Medicinal Hemp,” EarthX Young Professional (YPX), September 30, 2020
- “Legal, FDA, USDA Regulatory Update,” Steel, presenter, CBD Training Academy – Success Webinar, March 11, 2020
- Expert Live Q & A, to Texas Hemp Growers, Big Spring, Texas, March 7, 2020
- Hemp Laws in Texas, to Texas Hemp Federation Industry Stakeholder Meeting, Austin, Texas, February 13, 2020
- Expert Live Q & A, to Texas Hemp Growers, San Antonio, Texas, February 8, 2020
- Ask the Experts: Myth-Busting Legal & Practical Misconceptions About the Hemp Industry, to Texas Hemp Convention 2020, Dallas, Texas, January 30, 2020
- Expert Live Q & A, to Texas Hemp Growers, Bryan/College Station, Texas, January 25, 2020
- Expert Live Q & A, to Texas Hemp Growers, Dallas, Texas, December 7, 2020
Articles and Publications
- “Some Pa. stores sell Delta-8 THC, which promises a weed-like high. Is it legal?” York Daily Record, February 24, 2021
- “Your Guide to the USDA’s Final Rule on Hemp,” Hemp Grower, January 20, 2021
- “Cannabis Legal Low Down with Andrea Steel, Esq.,” Dr. Carlie (podcast), October 15, 2020
- “Cannabis Attorneys Push USDA to Fix Hemp Rule,” Law360, October 9, 2020
- “Did the DEA’s new rule confirm hemp-derived Delta-8 THC is illegal?” Texas Hemp Reporter, October 2020
- “Hemp farmers get last-minute delay on USDA compliance, but not everyone is happy,” Hemp Industry Daily, October 2, 2020
- “Smokable Hemp Ban in Texas, Temporary Injunction Granted – Win for Texas Manufacturers, Processors & Retailers,” September 17, 2020
- “The 2018 Farm Bill Does Not Support the DEA Interim Rule,” Harris Bricken, September 16, 2020
- “Hemp industry worries DEA rule puts extractors at risk, but path forward unclear,” Hemp Industry Daily, September 8, 2020
- “Did the DEA’s new rule confirm hemp-derived Delta-8 THC is illegal?,” with L. Pittman, Cannabis Business Executive, September 1, 2020
- “Criticized retail smokable hemp ban becomes official, and it’s stricter,” Texas Cannabis Collective, July 20, 2020
- “Clock Ticking on Two USDA Opportunities for Hemp Growers,” Hemp Industry Daily, July 15, 2020
- “Texas Medical Marijuana: “Incurable Neurodegenerative Disease,” October 18, 2019
- “TX Health Dept. Holds Public Hearing on Consumable Hemp Products,” October 4, 2019
- “How to Get a Medical Marijuana Dispensary License in Texas,” September 26, 2019
- Coats Rose Elevates Three Attorneys: Two to Director and One to Of Counsel, February 5, 2019
- Coats Rose Attorneys Worked with Provident Realty Advisors on The Star, Which Has Been Awarded the 2019 ULI Houston Development of Distinction Award, For-Profit Large Development
- Long Vacant Galveston Hotel Gets $10 Million Dollar Facelift, October 25, 2013
- Coats Rose Team Closes Redevelopment of Historic Texaco Building, September 17, 2013