It was "prearranged" by one month. This honestly just demonstrates how easy it is to game 10B5-1 plans.

I submitted this guy's newsletter separately, but it appears that SVB also lacked a Chief Risk Officer for most of 2022 and failed to explicitly disclose that until March 8 (i.e. two days ago).[1] It all looks pretty shady.

[1]: https://nongaap.substack.com/p/sivb-held-to-mortem-governanc... (submission: https://news.ycombinator.com/item?id=35098617)