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Yes. The two bolts for the tow hooks go into one plate.
Right, that's what I was thinking of then. I'm not sure self tapping screws/bolts would last too long just going through the rail. So you would need nuts. That's what the plate was for. The plate had nuts welded to it. The plate was the same size as the inner frame rail so that it wouldn't turn. Which means you wouldn't have to hold the hook nut when torquing down.
If your without one, it would be easy to fab one up. Mentioning this because the OP may have to go that route. Not sure how else you would have the ability to hold just a nut inside the frame otherwise. Unless the frame has cut outs for a wrench.