I do agree that so far, the SVB's HTM accounting seems to have been entirely compliant. Indeed, I think those rules are the root cause of the failure--if the SV

I do agree that so far, the SVB's HTM accounting seems to have been entirely compliant. Indeed, I think those rules are the root cause of the failure--if the SVB had been forced to mark to market, then they'd have recognized the loss earlier, causing them to raise equity (or wind down less abruptly) before the hole got so deep. Regulators can draft whatever they want, but if their rules depart too much from economic reality then bad stuff tends to happen. I think that's what happened here.