I think you have even more time to make a 7a close. SBA procedural notices (redacted) have indicated covered loans would need to move into regular servicing by 9/27/2020 to have loan subsidies applied. However, $17B has been appropriated for Sec 1112 funds and I have no idea how long they will last. Things have been changing quickly regarding CARES Act provisions, and banks have discretion as far as how the law & SBA procedures are applied, so you should check with your banker/servicer to validate your approach.

Would recommend just straight up calling your regional SBA contact, the banks have zero clue and are usually behind, timewise, as compared to having a direct POC at SBA. Everything changes daily at this point, lol.