No I'm not sure but I can't find any documentation that says AGI must be negative to have a NOL, only that AGI minus standard deduction must be negative. For simplification I have 9K capital gains, 5.5K business loss, and 12.2K standard deduction, which leads to -5.5K on the last line of Schedule A. What document says that AGI must be negative?
And yikes on the CARES act. Thanks so much for the head's up!