It's difficult to believe they top executives didn't know something was severely wrong in 2022 when they setup the sales.
If they knew this was coming, and that seems very likely, I wonder if there’s a law that could be used to claw that back/punish them.
They had 105b plans prepared, filed and approved by outside entities. You can see in the SEC documents and company filings all of the sales were pursuant to those plans, which are also commonly done to cover tax obligations throughout the year due to the vesting of stock.
KPMG passed SVB’s audit and several top financial firms had SVB’s default risk at around 2.5%.
The executives didn’t expect a “run on the bank” and those longer-term assets had been underwater for awhile & the financial market knew but expected they would be fine when they came to maturity.
They booked a loss to shift funds into shorter-term securities with higher yields to hedge and hindsight is 20/20 but they should’ve hedged sooner.
Overall, I don’t believe there was anything nefarious here & if we dislike the 105b rules, as many do, that should be the outcome of this review - that they need to change.