Yet I have suggested those flaws were essentially absolved by the belated action by the board.  100% concurrance.  I'd also suggest such issues then become moot.  Exigent circumstances were present.  Interpretations of the rules were being formulated by the govmt "on the fly".  Sometimes changing the SBA's Q&A day after day.  Even causing them to issue Q&A 17, clarifying who was to be bound by subsequently issued rules -- absolving those who relied upon the earlier rules.  It became an administrative quagmire, tangled web of bureaucratic & technocratic issues --a maze.  

Finally the SBA issued the news about conferring good faith onto all loans below $2 million.  Saving themselves so many nightmares -- cutting away a multitude of reviews they could likely never complete. 

Seems all these factors undercut the idea the OP would become a target.  And certainly not with any criminal intent.