yeah, kinda looks that way, you need atleast 1/2" of space cause the frame will flex a little and when it does, its going to eventually knock those flares loose a bit.

Another thing I noticed, If the guy that fabbed up your frame horns used the exsisting frame and just built off of it, I might be worried. Those frame horns are strong, but def not designed to take anymore stress like a winch pulling at max force. Maybe if he "boxed" in the frame with a plate in the front so you cant see inside it, might help out greatly.

My buddy had cut mine off completely past the factory tow hooks and attached it back from there. You want a smooth appoarch angle and nothing to hold you up if it gets close to those tow hooks. Just something to think about.

Angelo