CARES came later.  But was not applicable, because the rules allow organizations to rely on the rules in effect when they were applying.  I'd call that Q&A 17, but the OP Progress article merely described that principal as being applicable.  Also that article says their SBA's contacts were in that loop, discussing that time line, of which rules applied to OP's case.

You'll likely recall prior discussions of Q&A 17.  And you'll also recall the airlines illustration --  there's a difference between continuing operations vs going out of business.  These loans don't require dire consequences, like going-out-of-business level of distress.  Its a lower threshold 

You can check out those articles in the OP Progress to see what I've been  referring to.  Articles relevant to the PPP loan on its pages 6, 8, 9, 10, 12, 13 and 29. URL is   Click Here    

Tom