Yes. The director meets the definition of an associate.
(c) Definitions. As used in this section:
Associate is defined in section 3(8) of RESPA (12 U.S.C. 2602(8)).
Control, as used in the definitions of “associate” and “affiliate relationship,” means that a person:
(i) Is a general partner, officer, director, or employer of another person;
8) the term "associate" means one who has one or more of the following relationships with a person in a position to refer settlement business:
(A) a spouse, parent, or child of such person;
(B) a corporation or business entity that controls, is controlled by, or is under common control with such person;
(C) an employer, officer, director, partner, franchisor, or franchisee of such person; or
(D) anyone who has an agreement, arrangement, or understanding, with such person, the purpose or substantial effect of which is to enable the person in a position to refer settlement business to benefit financially from the referrals of such business;
The opinions expressed are mine and they are not to be taken as legal advice.