I must have missed something in the many changes since Basel II. I thought that one of the quasi-rules around hold-to-maturity classification was that it was not appropriate for highly liquid securities (like federal bonds). As interest rates rose, SVB moved its long term bond holdings into HTM accounting in order to prevent the reduction to its balance sheet. That’s exactly what mark-to-market was supposed to prevent. But not one is saying “misconduct,” so what they did must have been fair. So what am I missing?