On Friday, March 27, 2020, the Coronavirus Aid, Relief, and Economic Security
Act (or the "CARES Act") became law, marking the
third phase of government aid to combat the COVID-19 pandemic.
This $2 trillion stimulus package, the largest in American
history, will be accessed by wide swaths of the economy, with
similarly widespread potential for fraud. Consequently, the
accountability and oversight provisions built into the CARES Act,
especially of the $500 billion corporate relief fund, warrants
attention. Taking its cue from – and seemingly modeled
after – the 2008 Troubled Asset Relief Program
("TARP"), the CARES Act establishes a three-part
oversight structure, including a Special Inspector General for
Pandemic Recovery ("SIGPR") with far-reaching authority
to monitor the $500 billion fund. Based on the experience
with TARP oversight and the enforcement actions taken by the
Special Inspector General of TARP ("SIGTARP") over the
years, we can expect a high level
