at 742-44, and is not at issue in this appeal. 7 . We acknowledge a phrase like "arising out of” may be given a narrower scope in an exclusion when a court finds the exclusion ambiguous and therefore determines the phrase means "proximately caused by.” See Norwalk Ready Mixed Concrete, Inc. v. Travelers Ins. Cos., 246 F.3d 1132, 1138 (8th Cir. 2001). As we explain, however, we find the plain meaning of the underwriting exclusion here unambiguous. 8 . Farm Bureau's reliance on a Texas case involving an insured party not engaged in the practice of underwriting for the proposition that the claim here does not arise out of underwriting activity is unavailing. See HCC Empl'r Servs., Inc. v. Westchester Cnty. Surplus Lines Ins. Co., No. CIV.A. H-05-1275, 2006 WL 1663343, at *5 (S.D.Tex.2006) (<HOLDING>). Indeed, that court hinted its analysis may
holding foreign insurance company was supercorporation engaged in underwriting and selling insurance policies through its subsidiaries recognizing that insurance policy may lapse if the statutory renewal notice requirements are met holding failure to gain approval of insurance board for endorsement did not void regulatory exclusion holding negligent failure to notify regulatory body of lapse of insurance policy did not arise out of underwriting of insurance recognizing that production of a written insurance policy was unnecessary to prove the existence of the policy because the proof required was proof of the fact of insurance and not of the contents of a writing