Towers Financial Corporation: Jeffrey Epstein’s Role, Office Access, and the Hoffenberg Network
Snapshot
| Field | Documented information |
|---|---|
| Company | Towers Financial Corporation |
| Common abbreviation | Towers or TFC |
| Business | Receivables purchasing, debt collection and financing through notes and healthcare receivables bonds |
| Principal executive | Steven J. Hoffenberg, chief executive, president and chairman |
| Principal operating location | New York |
| Relevant subsidiaries | Towers Credit Corporation; Towers Collection Services; five Towers Healthcare Receivables Funding corporations |
| Insurance connection | United Diversified Corporation and its Associated Life and United Fire subsidiaries |
| Epstein connection | Consulting relationship alleged by Hoffenberg and supported by historical payment references and reporting |
| Historical office association | Villard Houses in Manhattan, according to contemporary investigative reporting |
| Early record naming Epstein | 1991 Illinois insurance regulator complaint, including a table of payments |
| SEC civil action | Filed February 8, 1993 |
| Bankruptcy | March 1993 |
| Hoffenberg guilty plea | April 20, 1995 |
| Criminal sentence | 20 years in prison; $475,157,340 restitution; $1 million fine |
| Epstein’s legal position in the Towers matter | No Towers-related criminal conviction established; later allegations against him were not adjudicated at trial |
| Later investor action | Gerber v. The Financial Trust Company, filed in 2018 and voluntarily dismissed without prejudice |
| Last checked | October 7, 2026 |
Towers Financial Corporation’s collapse produced a major securities fraud case, bankruptcy proceedings and years of investor litigation. The company sold debt instruments while presenting a misleading account of its receivables, income and use of investor money. Its former leader, Steven Hoffenberg, pleaded guilty and received a lengthy prison sentence.
Jeffrey Epstein’s connection to Towers is an important part of the record of his financial career, but it has a different evidentiary status from Hoffenberg’s conviction. Historical records identify payments to Epstein-related payees, while Hoffenberg later accused Epstein of helping design and operate the fraud. Those accusations were incorporated into civil complaints. A payment entry, a sworn accusation and a criminal judgment are not interchangeable forms of proof.
The correct corporate name is Towers Financial Corporation. It should not be confused with the separate Indiana banking business called Tower Financial Corporation, or with Epstein’s own Financial Trust Company. Similar names and overlapping abbreviations have contributed to unreliable summaries of the history.
Important Points
- Towers was a real receivables and collection business whose financing operation became a large fraud. Describing it simply as a mysterious shell omits how it attracted investors.
- Hoffenberg’s criminal responsibility was established through a guilty plea and sentence. The same judgment does not establish Epstein’s responsibility.
- The 1991 Illinois regulator complaint is an early documentary link. It lists payments totaling $215,000 to Epstein-related payees and alleges improper disbursements from insurance company funds.
- The payment tables are part of a pleading. They are not themselves canceled checks, a complete bank ledger or a criminal verdict against each payee.
- The failed Pan Am and Emery takeover efforts involved the use of insurance company assets, according to the sentencing court’s account of Hoffenberg’s conduct.
- The company’s notes and bonds were promoted using false financial statements and misleading collateral claims. Later investor money was used to sustain earlier obligations and operating expenses.
- Reports of Epstein’s consultancy and Manhattan office access are relevant to his professional position. They do not establish ownership of Towers or prove every alleged act of fraud.
- Hoffenberg’s later accusations require particular care because the court found that he breached a cooperation agreement, and later civil litigation raised questions about efforts to shift responsibility and represent victims.
- Hoffenberg withdrew his 2016 complaint with prejudice. Investors’ separate 2018 action was voluntarily dismissed without prejudice. Neither produced a trial finding against Epstein on the Towers allegations.
- A 2023 bank shareholder complaint repeated Towers allegations in a different dispute. Its presence in the DOJ release does not make its allegations government findings.
Corporate Identity and the Receivables Business
The 1991 Illinois complaint described Towers as a publicly held Nevada corporation with its principal place of business in New York. Its business model involved obtaining or servicing outstanding debts and collecting money owed. The financial value of that business depended on which debts the company actually owned, how collectible they were and how accurately those assets were reported.
The sentencing opinion in United States v. Hoffenberg distinguishes Towers Credit Corporation, which purchased commercial accounts receivable at a discount, from Towers Collection Services, which collected past due accounts for others for a fee. The difference matters. A debt collected as someone else’s agent is not automatically an asset the collector can pledge as its own collateral.
Towers also controlled five healthcare receivables funding corporations, generally referred to as the THRFC bond funds. These entities raised capital through bonds intended to finance purchases of healthcare receivables. Their corporate separation and collateral rules were central to the investment representations. A company could not legitimately support several sets of debt by moving the same purported collateral between funds or treating nonexistent receivables as genuine assets.
The later SEC filing concerning Tower Financial Corporation in Indiana describes a different bank holding company. It is not the New York Towers enterprise discussed here. Likewise, the Financial Trust Company named in later suits against Epstein is a separate defendant, not simply another name for Towers. Keeping the entities distinct is necessary before tracing any alleged movement of money between them.
Hoffenberg’s Control and the Corporate Network
The noteholders litigation described Hoffenberg as Towers’ chief executive, president and chairman, controlling 71 percent of its common stock in the record before that court. It identified distinct roles for other defendants: Charles Chugerman was an executive and board member, Arthur Ferro headed accounting, and Marvin Basson prepared audited financial statements. Their later guilty pleas were relevant to the civil claims against them.
The evidence of senior management, accountants and offering documents shows that the fraud depended on more than personal friendship between Hoffenberg and Epstein. Investors encountered corporate entities, financial statements, purported collateral, brokers and formal securities documents. The appearance of an established financial operation helped make the offerings credible.
Epstein’s alleged consulting role belongs within that setting. The documents reviewed do not establish that he held Hoffenberg’s corporate offices, controlled the same shareholding or appeared as a defendant in every regulatory action. A description such as associate or consultant should not be silently upgraded to chief executive, chairman or owner without the relevant corporate instrument.
The Insurance Companies and Failed Takeover Attempts
Judge Robert W. Sweet’s sentencing opinion recounts Towers’ acquisition of a controlling interest in United Diversified Corporation in 1987. United Diversified conducted business through Associated Life Insurance Company and United Fire Insurance Company. Regulatory approval depended on representations about capital to be supplied to the insurance business.
The court’s account describes the use of insurance company bonds as collateral for securities trading associated with attempted acquisitions of Pan American Airways and Emery Air Freight. The takeovers failed and the insurance companies suffered losses. It also describes checks drawn for expenses unrelated to the insurers’ legitimate business and efforts to obscure the location and use of their assets.
Illinois proceedings followed. The regulator’s 1991 pleading recites a conservation order entered in July 1988 and liquidation orders in March 1989. By then, the question was no longer simply whether a takeover strategy had succeeded. Regulators were addressing the financial condition of insurance companies holding obligations to policyholders and the use of their assets by the wider Towers group.
The later sentencing account identifies a May 4, 1992 settlement of the Illinois civil action, including a $3.5 million payment by Towers. It also explains that the companies’ loss and regulatory history were not accurately conveyed in Towers’ own financial reporting. The settlement and the criminal findings concerning Hoffenberg should not be treated as judgments that every person mentioned in the earlier complaint committed fraud.
The 1991 Complaint and the $215,000 Payment References
EFTA00612518 through EFTA00612556 preserve the Illinois regulator’s complaint in Schacht v. Hoffenberg and others, No. 91 C 4024. The pleading is dated June 27, 1991. Its defendants included Hoffenberg, other executives and the Towers entities. Epstein was named in its account of payments rather than as a defendant in the caption.
The tables on pages 11 and 12 list nine payments to Jeff Epstein or Jeffrey Epstein. Their amounts can be checked against paragraph 43, which gives a combined figure of $215,000 for checks payable to Epstein or an Epstein company. The date and amount associations below follow the page images rather than the often unreliable order of extracted text.
| Company account named in the complaint | Date | Payee as printed | Amount |
|---|---|---|---|
| United Fire Insurance Company | November 13, 1987 | Jeff Epstein | $25,000 |
| United Fire Insurance Company | December 1, 1987 | Jeff Epstein | $25,000 |
| United Fire Insurance Company | January 5, 1988 | Jeff Epstein | $25,000 |
| United Fire Insurance Company | February 1, 1988 | Jeff Epstein | $25,000 |
| United Diversified Corporation | March 1, 1988 | Jeff Epstein | $25,000 |
| United Diversified Corporation | March 2, 1988 | Jeff Epstein | $20,000 |
| United Diversified Corporation | March 4, 1988 | Jeffrey Epstein | $25,000 |
| United Diversified Corporation | April 6, 1988 | Jeff Epstein | $20,000 |
| United Diversified Corporation | May 3, 1988 | Jeff Epstein | $25,000 |
| Total of these nine entries | 1987 and 1988 | Epstein-related payees | $215,000 |
Paragraph 43 alleges that Hoffenberg at different times characterized the payments as brokerage fees or investment advice associated with Emery. This is stronger evidence of a contemporary financial connection than a later unsupported name association. It is still a regulator’s pleaded account of disbursements and explanations.
The records do not provide a full contract, invoices, bank reconciliation or adjudication of what Epstein knew about the source and intended use of every payment. Nor does a similar payee name conclusively establish the precise incorporated identity of an Epstein business. These are reasons to preserve the documentary detail, not reasons to erase it or convert it into a broader finding.
Epstein’s Consultancy and the Villard Office Association
Vicky Ward’s 2003 Vanity Fair investigation reported that Hoffenberg hired Epstein as a consultant at $25,000 per month and provided office space at the Villard Houses in 1987. It also reported Epstein’s denial of involvement in financing the takeover bids. These are attributed reporting claims, not a reviewed lease or consulting contract.
The office account is relevant because it places Epstein in a professional environment associated with Hoffenberg’s business and access to capital. Office access can show proximity and opportunity to work together. It does not by itself identify a legal employer, prove ownership of the premises or establish control of every account associated with the company.
Hoffenberg’s 2018 affidavit supplies a separate source for the relationship. He said he hired Epstein around 1987 as an associate and expert consultant assisting with operations, management and fundraising. The affidavit then made much broader accusations of criminal participation. The existence of a consulting relationship and the truth of those broader accusations require separate evaluation.
The historical Villard association also should not be confused with Epstein’s later residences, other offices or the present activities of anyone occupying the property. There is no need to publish current access arrangements, occupant information or building security details to explain the financial history.
How the Notes and Bonds Fraud Worked
The criminal sentencing record describes approximately $272 million in promissory notes sold through offerings dated from January 1988 through March 1992. Investors were told the notes were supported by receivables and Towers’ assets. In reality, financial statements overstated income and assets, some purported receivables were fictitious, and some debts counted as collateral were not owned by Towers.
The same opinion describes roughly $210 million in bonds sold through the healthcare receivables entities between July 1990 and May 1992. Those offerings similarly relied on misleading accounts of collateral, revenue and financial strength. Proceeds were diverted to operating needs rather than used only for the represented receivables purchases.
The SEC’s February 1993 announcement identifies the underlying misconduct alleged at the start of its civil case: unregistered note offerings, misstatements about receivables and fee income, and misrepresentations about the use of investor money. It separately alleged insider trading by Hoffenberg based on knowledge of the company’s real financial position.
The mechanism was not merely that a risky investment lost money. Investors were supplied a false picture of the assets backing their investments, while incoming money supported obligations and expenses that the stated business could not sustain. Fabricated accounting and misleading collateral reports concealed that dependence. The criminal findings established this conduct as to Hoffenberg; later allegations identifying Epstein as the designer of particular steps were separate claims.
SEC Action, Bankruptcy and the New York Post Connection
The SEC filed its civil action on February 8, 1993, naming Towers, Hoffenberg, Mitchell Brater and Arthur Ferro. The case was not a criminal indictment of Epstein. Its initial allegations and later judgments should be described by the people and entities actually named.
The amended complaint announced in March 1993 added the five healthcare receivables subsidiaries and three entities connected with the New York Post as relief defendants. The SEC alleged that fraudulently obtained money had reached, or was expected to reach, those entities in connection with Hoffenberg’s newspaper acquisition efforts. Naming a relief defendant concerns recovery of alleged proceeds and is not the same as finding every employee of that entity responsible for the underlying fraud.
Towers entered bankruptcy in March 1993. Bankruptcy and securities litigation then addressed the company’s assets, investor claims, professional advisers and the responsibility of its officers. The collapse ended the business’s ability to sustain the financial representations on which its notes and bonds had been sold.
The SEC’s November 1994 notice records a consent judgment against Hoffenberg, with an injunction, disgorgement, interest, penalties and a public company officer and director bar. That civil resolution was entered without his admitting or denying the complaint’s allegations. His subsequent criminal guilty plea is a distinct event with a different legal effect.
Criminal Accountability and Investor Judgments
The court’s later procedural account records Hoffenberg’s April 20, 1995 guilty plea to five counts covering securities conspiracy, mail fraud, obstruction conspiracy, tax evasion, and mail and wire fraud. He received 240 months in prison and a restitution obligation of $475,157,340. The conviction and sentence were affirmed.
The sentencing opinion explains the restitution figure through allowed noteholder and bondholder claims. It distinguished those losses from the separate Illinois insurance losses. Consequently, descriptions such as a roughly $475 million fraud and references to a larger aggregate loss may concern different accounting scopes. The figures should not be added repeatedly as if each represented a separate pool of victims’ money.
The opinion also describes obstruction of the SEC investigation, including false testimony and fabricated financial records. The criminal case was therefore about both the underlying financial conduct and efforts to frustrate scrutiny. That history is relevant when assessing later representations by the convicted executive about who bore responsibility.
The January 1998 noteholders decision granted summary judgment against Hoffenberg, Basson, Ferro and Chugerman based on their guilty pleas. Its supplemental order corrected an earlier typographical amount and directed judgment of $250 million against those defendants. This civil judgment is not a separate criminal conviction, and an overlapping civil award is not proof of an additional $250 million loss beyond the underlying scheme.
None of these cited judgments convicted Epstein of Towers-related conduct. The sentencing opinion’s references to co-conspirators do not identify every possible participant, and they cannot be treated as a judicial finding against a person whom the opinion does not name.
Hoffenberg’s Cooperation and the Reliability Problem
United States v. Hoffenberg, 908 F. Supp. 1265 addressed Hoffenberg’s attempt to enforce a cooperation agreement after prosecutors terminated it. The court found that he had breached the agreement. This is material context for later claims that depend heavily on his account of what he told investigators or why another person was not prosecuted.
A convicted insider can possess important firsthand knowledge. A history of dishonesty does not make every later statement false. It does mean that a responsible account should seek corroboration and distinguish records created near the events from accusations made decades afterward in litigation seeking money or relief.
The 1991 payment references, the sentencing findings about Hoffenberg and the 2018 allegations against Epstein serve different purposes. They should be compared rather than merged into a single narrative in which all sources supposedly prove the same thing. Equally, Epstein’s absence from a criminal judgment does not prove that every question about his consulting work was resolved in his favor.
The Later Restitution Campaign and 2016 Lawsuit
A December 18, 2013 order illustrates the problems surrounding a later restitution campaign. Judge P. Kevin Castel questioned a petition that purported to represent a very large body of Towers investors while seeking changes to Hoffenberg’s supervised release. The order raised concerns about the same lawyers representing both Hoffenberg and his victims, and directed a response concerning possible dismissal, sanctions and disqualification.
The order also recounted the petition’s claim that Epstein’s wealth could provide restitution. That was the court describing an assertion made to it, not validating the claimed scale or source of Epstein’s fortune. The petition’s large number of supposedly represented investors should not be adopted as an independently established count merely because it appeared in a case caption.
Hoffenberg’s July 1, 2016 withdrawal letter, in Hoffenberg v. Epstein, No. 16-cv-3989, requested withdrawal of his complaint with prejudice. His lawyers said Towers’ victims might be better placed to pursue their own claims. The letter records a decision to end that action, not a damages award or a finding that Epstein financed his later businesses with stolen Towers funds.
The later affidavit acknowledged that the 2016 case was withdrawn with prejudice. That outcome must accompany the existence of the complaint. Citing a suit without its withdrawal can make an untested allegation appear to remain an active or successful judicial claim.
The 2018 Investor Complaint, Defense and Dismissal
Gerber v. The Financial Trust Company was filed on August 20, 2018 by Marvin Gerber and Kalma Koenig on behalf of a proposed class of Towers noteholders and bondholders. It alleged that Epstein had participated in the fraud and used its proceeds for businesses he controlled. The complaint attached or relied upon Hoffenberg’s account and sought to connect the old Towers losses to Epstein’s later financial position.
Hoffenberg’s affidavit, filed as Document 7-2, alleged that Epstein helped arrange the insurance transactions, securities activity, false financial reporting and fundraising. It also acknowledged that Epstein had not been charged for the conduct. These are sworn accusations by Hoffenberg. They were not findings made after a trial of Epstein.
The defense memorandum preserved in EFTA00802452 challenged the claims as stale and characterized the case as an attempt by Hoffenberg to shift responsibility. The released copy bears an attorney work product heading rather than a court filing stamp. The public docket independently confirms that Epstein and Financial Trust filed a motion to dismiss and supporting memorandum on September 14, 2018. The arguments remain the defendants’ positions, not the judge’s conclusions.
EFTA00802936 and EFTA00802937 contain the plaintiffs’ October 5, 2018 notice of voluntary dismissal without prejudice and without costs. The case ended without a trial establishing the alleged transfer of Towers proceeds to Epstein’s later companies. Without prejudice preserves a procedural distinction from Hoffenberg’s 2016 withdrawal, but it does not make the dismissed allegations proven.
Towers in the 2023 Bank Shareholder Litigation
The June 30, 2023 amended derivative complaint against JPMorgan officers and directors, Document 17 in No. 23-cv-3903, revisited Towers as part of an argument about warning signs in Epstein’s financial history. It repeated accounts of his consultancy, Hoffenberg’s accusations and the Villard office association, including material derived from earlier reporting. The pleading is also indexed in the released court records as EFTA02822837 and following pages.
Its function was to argue what bank decision makers should have known or investigated. It was not a new prosecution of Towers and did not establish Epstein’s liability for the old fraud. Some of its historical wording is inconsistent: one paragraph places Hoffenberg’s conviction in 1993, while another refers to the 1995 guilty plea. The original criminal record supplies the correct plea chronology.
Judge Jed S. Rakoff issued the dismissal opinion on January 12, 2024, confirming dismissal with prejudice after an August 2023 preliminary order. The opinion addressed the plaintiffs’ failure to satisfy the requirements for proceeding without first making a litigation demand on the board. That disposition should not be presented as either a Towers conviction or a trial exoneration of Epstein. It concerned a different lawsuit, against different defendants, under different legal requirements.
Evidence Appearances
| Record | Date | What it documents | Principal limitation |
|---|---|---|---|
| EFTA00612518 through EFTA00612556 | June 1991 | Illinois regulator complaint and disbursement tables naming Epstein-related payees | Pleading, not verdict against each named payee |
| SEC Litigation Release 13514 in the News Digest | February 1993 | Initial federal securities civil action | Allegations at filing; Epstein was not a named defendant |
| SEC Litigation Release 13550 in the News Digest | March 1993 | Expanded defendants and New York Post-related relief defendants | Receipt of alleged proceeds is distinct from adjudicated responsibility |
| SEC Litigation Release 14317 in the News Digest | November 1994 | Hoffenberg’s civil consent judgment | Entered without admission or denial |
| EFTA01120705 through EFTA01120715 | March 1997 opinion, later reproduced | Hoffenberg’s sentencing opinion and corporate fraud history | A commercial reprint of a court opinion; it does not name Epstein as a convicted participant |
| Noteholders judgment, 996 F. Supp. 266 | January 1998 | Civil judgment against four defendants based on guilty pleas | The supplemental order corrects the monetary amount to $250 million |
| EFTA00618266 through EFTA00618270 | December 18, 2013 | Court’s concerns about a restitution petition and representation | A show cause order is not itself every later sanction or final outcome |
| EFTA00594947 | July 1, 2016 | Hoffenberg’s request to withdraw his complaint with prejudice | No trial finding against Epstein |
| EFTA01433867 | August 20, 2018 | Investor complaint | Allegations, not an adjudication |
| EFTA00811809, pages 44 through 51 | Filed August 21, 2018 | Hoffenberg affidavit attached to the refiled complaint | Insider account requiring corroboration |
| EFTA00802452 | September 2018 | Defense memorandum in the released files | Work product copy; defense arguments are not judicial findings |
| EFTA00802936 through EFTA00802937 | October 5, 2018 | Voluntary dismissal of the investor action | Without prejudice and without a merits trial |
| Document 17, EFTA02822837 | June 30, 2023 | Later shareholder pleading repeating historical Towers allegations | Released pleading and quoted reporting do not become DOJ findings |
Chronology
| Date or period | Development |
|---|---|
| 1980s | Towers operates receivables and collection businesses under Hoffenberg |
| 1987 | Acquisition of United Diversified and its insurance subsidiaries; reported beginning of Epstein’s consultancy |
| 1987 and 1988 | Failed takeover efforts and disbursements later challenged by Illinois regulators |
| July 1988 and March 1989 | Insurance company conservation and liquidation proceedings |
| June 1991 | Illinois regulator complaint lists Epstein-related payments |
| May 1992 | Settlement of the Illinois civil action described in the sentencing opinion |
| February 8, 1993 | SEC files its civil case |
| March 1993 | Towers bankruptcy |
| February 1994 | Hoffenberg arrested after termination of his cooperation agreement |
| April 20, 1995 | Hoffenberg pleads guilty |
| 1997 | Hoffenberg sentenced to 20 years and substantial restitution |
| January 1998 | Civil judgment against Hoffenberg and three other defendants |
| December 2013 | Court questions later restitution petition and representation arrangements |
| July 2016 | Hoffenberg withdraws his Epstein complaint with prejudice |
| August to October 2018 | Investor action filed, challenged and voluntarily dismissed without prejudice |
| June 2023 | Bank derivative complaint repeats Towers history as alleged warning signs |
| January 2024 | Derivative case dismissed with prejudice |
What the Record Establishes and What Remains Unresolved
The corporate record establishes a serious financial fraud, the failure of a financing model supported by false accounting, major investor losses and criminal responsibility for Hoffenberg and other convicted defendants. It also establishes a documentary basis for examining Epstein’s paid connection to the business. The early regulator complaint and later affidavit should both remain visible, with their different dates and purposes intact.
The unresolved issue is the extent of Epstein’s responsibility for the fraud, rather than whether the entire company history was invented. The reviewed material does not establish a Towers criminal charge or conviction against him, nor does it provide a complete tracing of Towers money into his later fortune. The withdrawal of civil actions leaves allegations untested; it does not automatically prove either the allegations or their opposite.
An evidence-based company profile therefore needs both layers: how Towers operated and collapsed, and exactly what the records say about Epstein’s role. Treating his association as a verdict obscures the legal history. Treating the absence of a verdict as a reason to omit the payment records and sworn allegations obscures the documentary history.
Related Articles
- Steven Hoffenberg
- Jeffrey Epstein
- Bear Stearns
- Jeffrey Epstein’s 1981 SEC Testimony and Bear Stearns Exhibits
- Darren Indyke
Sources
- Schacht v. Hoffenberg and others, EFTA00612518: June 1991 complaint, especially pages 1 through 3 and 11 through 14.
- SEC News Digest, February 9, 1993: announcement of the February 8 civil action, Litigation Release 13514.
- SEC News Digest, March 15, 1993: amended complaint, Litigation Release 13550.
- SEC News Digest, February 18, 1994: Hoffenberg arrest announcement.
- SEC News Digest, November 3, 1994: consent judgment, Litigation Release 14317.
- United States v. Hoffenberg, 908 F. Supp. 1265: cooperation agreement ruling.
- United States v. Hoffenberg, 1997 WL 96563, EFTA01120705: sentencing opinion and account of the company’s operations.
- In re Towers Financial Corporation Noteholders Litigation, 996 F. Supp. 266: January 1998 judgment and correction.
- Hoffenberg v. Hoffman & Pollok, 248 F. Supp. 2d 303: procedural history of bankruptcy, plea and sentence.
- Vicky Ward, The Talented Mr. Epstein: March 2003 reporting on consultancy, office access and Epstein’s denial.
- EFTA00618266: December 2013 restitution petition order.
- EFTA00594947: July 2016 withdrawal letter.
- EFTA01433867 and EFTA00811809: 2018 complaint and related filing packet with Hoffenberg affidavit.
- EFTA00802452, EFTA00802936 and Gerber docket: defense position, filing history and voluntary dismissal.
- Operating Engineers v. Dimon, Document 17, readable court-document transcription: June 30, 2023 amended derivative complaint; DOJ collection counterpart.
- Operating Engineers v. Dimon, Document 42: January 12, 2024 dismissal opinion.
- Tower Financial Corporation SEC exhibit: separate Indiana company, included to prevent mistaken identity.