That sounds right to me. I didn't find anything in Reg O that specifically says that but that would seem to fit with the intent of the reg. Maybe they are deriving it from the following general description in Reg O in 215.3(a)
(7) "Any other similar transaction as a result of which a person becomes obligated to pay money (or its equivalent) to a bank, whether the obligation arises directly or indirectly, or because of an endorsement on an obligation or otherwise, or by any means whatsoever."
It also would seem to fall under the "tangible economic benefit" rule since it sounds like the director's company will be receiving commissions from the eventual sales of the homes.
It also looks like as R.L. Carey has stated previously to be a self-dealing conflict of interest situation.
I think if I was going to make this loan I would want a legal opinion on it prior to doing so.
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Not a legal opinion, just my personal opinion.
"A nickel isn't worth a dime today."- Yogi Berra