Yeah. The only justification for HTM accounting is an expectation that depositors will be irrationally "sticky", i.e. that when interest rates increase they won't move their money to a bank (or Treasury bill, etc.) offering a correspondingly increased return. It's a real economic loss no matter what; the HTM accounting just assumes that the depositors' irrational behavior will allow the bank to earn its way out of it. For the SVB it clearly didn't.