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On Friday, March 27, 2020, President Trump signed into law the Coronavirus Aid, Relief, and Economic Security Act (the “CARES Act”), which provides $2 trillion in economic stimulus for industries and individuals faced with challenges from the COVID-19 coronavirus.

In its recent decision, Executive Benefits Insurance Agency v. Arkison (In re Bellingham Insurance Agency, Inc.),1 the Supreme Court reiterated and expanded on the reasoning in Stern v.