No, they are not. The requirement to take RMDs is established in section 401(a)(9). In the second paragraph of my most recent reply, "this paragraph" refers to section 401(a)(9). Perhaps I should have quoted more of the CARES Act, but I provided a link to it instead. Rephrasing the CARES Act, it says, "IN GENERAL.—The requirements of section 401(a)(9) shall not apply for calendar year 2020 ..." The unmodified text becomes part of section 401(a)(9), which is why "this paragraph" means section 401(a)(9).
