Are spouses of directors governed by Regulation O?

They can be. One audit check is to see if loans were made to spouses in lieu of making them to the insider. This is especially true if the borrower lacks the means to repay the debt on their own an a reliance was made on the insider's income.

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Andy Zavoina
Opinions stated are not necessarily that of my employer.

Also keep in mind the fact that a loan to a spouse of a director may, in some instances, be considered an extension of credit to the director under the "tangible economic benefit rule." Under Reg O, in Section 215.3(f), it explains:

(f) Tangible economic benefit rule--(1) In general. An extension of credit is considered made to an insider to the extent that the proceeds are transferred to the insider or are used for the tangible economic benefit of the insider.
(2) Exception. An extension of credit is not considered made to an insider under paragraph (f)(1) of this section if:
(i) The credit is extended on terms that would satisfy the standard set forth in Sec. 215.4(a) of this part for extensions of credit to insiders; and
(ii) The proceeds of the extension of credit are used in a bona fide transaction to acquire property, goods, or services from the insider.

Also, shares of stock that the spouse owns in a company would be aggregated with shares the director owns in the same company to determine whether the director owns or controls the company, which would then make the company a related interest.