Courts in other states have similarly limited the 30-day notice provision under the CARES Act to nonpayment cases (see Watson v Vici Community Dev. Corp., 2022 WL 910155, *9-10, 2022 US Dist LEXIS 55211, *25-27 [WD Okla, Mar. 28, 2022, No. CIV-20-1011-F]; CP Commercial Props., LLC v Sherman, 53,897-CA [La App 2d Cir 4/14/21] at 5, 318 So 3d 445, 449 [2021] ["Paragraph (c) sets forth when notice to vacate may be sent following the moratorium stated in paragraph (b). However, that moratorium is not even applicable in this matter as it applies to 'legal action to recover possession of the covered dwelling from the tenant for nonpayment of rent or other fees or charges(.)' The eviction at issue is premised upon the ending of the lease period"]; MIMG CLXXII Retreat on 6th, LLC v Miller, 16 NW3d 489, 501 [Iowa 2025] ["In the end, we believe that the most correct interpretation of 9058(c)(1) is that it applies only to rent defaults that arose during the moratorium—the subject of the rest of section 9058—and not to any default at any time for any reason"]).
The rationale behind these rulings appears to be uniform: all subsections of 15 USC § 9058 should be read together, not bifurcating subsections (b) and (c) as respondent advocates, and, when reading all subsections together, it is clear that said subsections are all subject to the same limit—they apply only to nonpayment proceedings.