Nor can the banks make the reasonable assumption that a young couple wanting to buy their first home would be likely to cut down on takeaway coffees or other discretionary spending to avoid defaulting on their loan.
The risk for making a subjective assessment is real, with senior managers potentially liable for a $200,000 fine. You can hardly blame a credit manager for taking a conservative approach with that hanging over them.
Clark told Newstalk ZB's Mike Hosking that a lot of the media articles he was seeing were about homebuyers who did not have a 20 per cent deposit.
"I can't answer for the media, I wish that I could," Clark said of the stories. He told Hosking that his hunch, so far, was that the new rules - designed to stop borrowers falling into unmanageable debt - were working as necessary.
If Clark's assessment is based on the people complaining publicly, he is badly misinformed by selection bias.
First home buyers are a visible, politically important and often noisy group. But they are only part of consumer lending covered by the CCCFA.
Clark, who also made an inflammatory suggestion that New Zealand's banks had not been following the responsible lending rules that applied before the changes, held meetings with bank bosses this week.
Here he is likely to have been told how the new lending rules affect a much broader group than just those trying to get onto the property ladder.
As anyone who has called their bank knows, the calls are recorded. These have apparently recorded an exercise in mass frustration.
As well as hopeful home buyers, customers with lengthy relationships with the bank are being recorded in shock that they cannot get what they see as minor changes to their loans, at least without a lengthy and intrusive assessment.
Customers who need emergency loans, say for car repairs or medical bills, are discovering the process is so lengthy and uncertain, one banking figure said, that they are better off going to high-interest payday lenders.
If that seems ironic, it might be topped. One banking figure said he had heard examples of a customer wanting to consolidate their borrowing with loan sharks into a personal loan with a bank, but being told the bank could not approve the loan because of the CCCFA.
Bigger problems may be looming. While business loans are not covered by the CCCFA, many small business owners use their homes as security for business debt. When times are lean, they extend their mortgage.
This is likely to create headaches for business who are, right now, dealing with an Omicron-induced shadow lockdown, where a chunk of the population is imposing their own stay-at-home restrictions.
"There will be strain coming into the marketplace," Keith McLaughlin, managing director of credit reporting agency Centrix, told RNZ on Wednesday, predicting businesses would find it harder to access credit.
"That will impact businesses' ability to continue to trade effectively."
Economist Tony Alexander says aspiring buyers hit by the rules can - and should - change their behaviour immediately, cut back on discretionary spending, and they might meet the test of the legislation in three months.
This may not be an option for a business owner who needs help to tide them over now.
Clark now says he is open to tweaks of the new rules, but continues to grip to the idea that changes in overall lending could be down to any number of reasons, adding vacuous assurances that the banks agree with the intent of the changes.
But right now, the rules are simply adding to existing strain on a banking system already dealing with the factors Clark repeatedly says may be causing problems, from global economic concerns, to rising interest rates and other lending restrictions.
