tein misappropriated the proceeds for personal use in connection with his investment business. 23. In order to win approval for the Acquisition by the Illinois Department of Insurance, Hoffenberg, Epstein and other individuals of TFC, promised to invest new capital in the amount of $3,000,000 in each of the Subsidiaries pursuant

violations of the securities laws. An in- vestigation was also commenced in the Northern District of Illinois with respect to a scheme to de- fraud the Illinois Department of Insurance and two Illinois insurance companies acquired by Towers. In March 1993, Hoffenberg and the Government Page 7 of 20 Page 6 agreed that Hoffenberg