Can tow hook brackets be Bumper mounts?

I have a home made bumper that mounts with only 3 bolts per side. I want to reinforce it using a set of tow hooks with COMPLETE brackets.

Is this strong enough?

The bumper has shackle tabs, and I won't use them until I beef up the mounts.

Other option is selling the hooks and putting on a Drawtite front receiver.

Can any one show me how high and tight to the front crossmember that receiver is? Preferably with the stock bumper off. Or measure the distance from the top of the hitch mount to the bottom of the grill, or the moulding around the grill.... Basically any info on where this hitch sits would help.

My bumper is currently mounted with just the 3 stock mounting bolts. This is O.K. if I don't use it to pull or be pulled. I plan to incorporate a reinforcement plate to the rear of the existing mounts with another cover plate covering the top of both parts and bolted in several places. I guess the answer is as long as you don't pull or be pulled by it then you should be fine.

it might be a pain to weld the tow hook tie ins to the bumper.....if you could mount the bumper mounts over the tow hook tie ins, that might work......maybe....the steering box bolts would have to be uber long.