State Universities Retirement System of Illinois (SURS)

Request for Proposal

Private Equity Emerging Manager Fund-of-Funds Services

2015

Table of Contents

I. Request For Proposal Summary Statement 3

II. Background Information 3

III. Specific Services Requested from the Investment Manager 5

IV. Diversity Goals 6

V. Minimum Qualifications 6

VI. RFP Specifications 7

VII. Projected Schedule of Events 10

Appendix A – Minimum Qualifications Certification 11

Appendix B – Disclosures per Illinois Pension Code Section 1-113.21 12

Associated Documents (Attachments)

Appendix C – SURS Questionnaire and Price Sheet (Word document)

Appendix D – NEPC Questionnaire (Word document)

Appendix E – NEPC Questionnaire – Fund Level Performance (Excel document)

Appendix F – NEPC Questionnaire – Fund Cash Flows (Excel document)

Appendix G – NEPC Questionnaire – Deal-by-Deal Track Record (Excel document)

Appendix H – Employee Diversity Chart

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State Universities Retirement System (SURS)Request for Proposal (RFP)

November 2015

Private Equity Emerging Manager Fund-of-Funds Provider Search

I. RFP Summary StatementThe State Universities Retirement System of Illinois (“SURS” or “System”) is requesting proposals from qualified firms interested in providing Private Equity Emerging Manager Fund of Funds Advisory Services (“Proposers”). One or more firms will be considered to manage approximately $100 million in total. All forms/required documents needed for submitting a Request for Proposal (“RFP”) are available on the IL SURS website at www.surs.org .

Respondents must answer all applicable questions in the questionnaire sections in order to be considered.

II. Background Information Agency DescriptionSURS is the administrator of a cost-sharing, multiple employer public employee retirement system. SURS membership includes employees of the Illinois public universities and other affiliated organizations. Currently, SURS membership totals more than 200,000 active, inactive and retired participants. SURS maintains both a defined benefit plan (DB plan) and defined contribution plan. Proposals are being solicited for the defined benefit plan. To learn more about the fund, you may visit our website at www.surs.org.

Defined Benefit Plan Investment ProgramAs of June 30, 2015, the DB plan trust totaled $17.4 billion with a target asset allocation as follows:

TargetU.S. Equity 23%Non-U.S. Equity 19%Global Equity 8% Core Fixed Income 19% Emerging Markets Debt 3%TIPS 4%Private Equity 6% Real Estate 6% REITS 4% Hedged Strategies 5%Opportunity Fund 1%Commodities 2%

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Legislated Investment Restrictions Relating to the Republic of the Sudan and IranEffective January 1, 2016, Section 1-110.16 of the Illinois Pension Code (40 ILCS 5/1-110.16) generally requires SURS to divest from direct holdings in “restricted companies” consisting of:

1. Certain companies that boycott Israel by engaging in actions that are politically motivated and are intended to penalize, inflict economic harm on, or otherwise limit commercial relations with the State of Israel or companies based in the State of Israel or in territories controlled by the State of Israel;

2. Certain companies that have business operations that involve contracts with or provision of supplies or services to the Government of Iran, companies which the Government of Iran has any direct or indirect equity share, consortiums or projects commissioned by the Government of Iran, or companies involved in consortiums or projects commissioned by the Government of Iran; and

3. The government of Sudan and any of its agencies, companies under control of Sudan, companies established or organized in Sudan, companies identified or prosecuted by the Office of Foreign Assets in the U.S. Treasury Department as sponsoring terrorist activities in Sudan, or any publicly traded company whose principal place of business is in or conducts business in Sudan.

“Private market funds” (which include private equity funds and private equity fund-of-funds) are not subject to the divestment provisions. However, the Illinois Investment Policy Board will request that a private market fund manager consider removing restricted companies from the fund or create a similar actively managed fund having indirect holdings devoid of the companies. If such a fund is created, SURS is required to replace all applicable investments with investments in the similar fund in an expedited timeframe consistent with prudent investing standards.

State Fiduciary, Ethics, and Diversity LawsSections 1-109, 1-109.2, 1-110, 1-125. 1-130, 1-135, and 1-145 of the Illinois Pension Code (40 ILCS 5/1-109, 1-109.2, 1-110, 1-125, 1-130, 1-135, 1-145) contain fiduciary, ethics, and prohibited transaction provisions that may apply to investment managers.  Investment managers seeking to be considered for this mandate should be familiar with and must comply with such applicable provisions of the Illinois Pension Code.

Section 1-109.1 of the Illinois Pension Code (40 ILCS 5/1-109.1) encourages the Board to increase the use of minority-owned businesses, female-owned businesses, or businesses owned by persons with disabilities as emerging investment managers, minority investment managers, broker-dealers, or vendors for services and contracts; and to increase the racial, ethnic, and gender diversity of its fiduciaries (including investment managers and consultants), to the greatest extent feasible within the bounds of financial and fiduciary prudence. To this end, the Board encourages minority-, female- and persons with a disability-owned investment managers to submit proposals to this RFP.

Section 50-37 of the Illinois Procurement Code concerning prohibitions on political contributions for certain vendors (30 ILCS 500/50-37) may or may not apply to SURS investment managers or

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consultants.  SURS is not subject to the Illinois Procurement Code, generally (30 ILCS 500/1-15.100).  However, each investment manager and consultant should be familiar with the provisions of section 50-37 of the Procurement Code and comply with this section if the investment manager or consultant deems it appropriate.

Additional Disclosure RequirementsSection 1-113.21 of the Illinois Pension Code (40 ILCS 5/1-113.21), added by Public Act 98-1022, effective January 1, 2015, provides that no contract, oral or written, for investment services, consulting services, or commitment to a private market fund shall be awarded by a retirement system, pension fund, or investment board established under the Code unless the investment advisor, consultant, or private market fund first discloses:

(1) the number of its investment and senior staff and the percentage of its investment and senior staff who are (i) a minority person, (ii) a female, and (iii) a person with a disability; and

(2) the number of contracts, oral or written, for investment services, consulting services, and professional and artistic services that the investment advisor, consultant, or private market fund has with (i) a minority owned business, (ii) a female owned business, or (iii) a business owned by a person with a disability; and

(3) the number of contracts, oral or written, for investment services, consulting services, and professional and artistic services the investment advisor, consultant, or private market fund has with a business other than (i) a minority owned business, (ii) a female owned business or (iii) a business owned by a person with a disability, if more than 50% of services performed pursuant to the contract are performed by (i) a minority person, (ii) a female, and (iii) a person with a disability.

Each Proposer responding to this RFP must disclose this information in the form provided in Appendix B.

III. Specific Services Requested from the Investment ManagerSURS is requesting information from qualified firms to manage a private equity emerging manager fund-of-funds portfolio. It is expected that 100% of the underlying funds in the portfolio will be managed by firms owned by emerging investment managers, as defined by Illinois law1. This search is not focusing on the manager-of-manager organization being qualified as a firm owned by minorities, females, or persons with a disability (MFDB); rather, it is focused on the strategy being MFDB-focused. To the degree that the proposing manager-of-managers is a qualified MFDB firm, that characteristic will be considered. SURS is seeking a portfolio that will be diversified across key private equity strategies, and prefers the inclusion of venture capital, buyout, special situation, mezzanine and distressed/restructuring partnerships. SURS prefers the portfolio to be primarily

1 Illinois statute (40 ILCS 5/1-109.1(4)) defines “emerging investment manager” to mean "a qualified investment adviser that manages an investment portfolio of at least $10,000,000 but less than $10,000,000,000 and is a ‘minority owned business’, ‘female owned business’ or ‘business owned by a person with a disability’ as those terms are defined in the Business Enterprise for Minorities, Females, and Persons with Disabilities Act” (30 ILCS 575/2(A), (B)).

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domestic (U.S.) in orientation, but geographically diversified across U.S. regions. SURS intends for this initiative to be ongoing and is seeking diversification across vintage year and by industry sector.

SURS will consider the following evaluation criteria in making its decision: Stability and General Experience of the Firm – as measured by the stability of the financial

condition of the firm and experience in providing private equity fund-of-funds management to institutional clients.

Key Personnel – Personnel to be assigned to this account, including key professionals, applicable portfolio managers, back-up and other staff assistance, and education and experience of all such key personnel.

Expertise – (a) Similar work performed for other clients, with references of such funds to be specified in proposal; (b) Assets under management; and (c) Investment experience broadly defined and experience as a manager of private equity funds, specifically those funds managed by emerging investment managers.

Client references – as measured by the quality of the references provided. Performance – Prior funds’ performance measured on both an absolute and relative basis. Investment Process – Consistent process implementation, as measured by return consistency,

portfolio construction methodology, and the implementation of risk controls. Investment Philosophy and Style – The extent to which the proposed philosophy and style

best complement existing philosophies and styles and meet the requirements and expectations as presented in this RFP.

Access to Recognized Top Tier Emerging Manager Partnerships – The manager should exhibit historical investor relationships with partnerships generally recognized as being among the best at employing an emerging manager strategy.

Fees – Reasonableness and competitiveness of fees, as well as transparency in reporting of fees of underlying managers.

RFP Proposal – Completeness, clarity and responsiveness to requirements as requested in the RFP and accompanying template.

IV. Diversity Goals : SURS has established a goal that 20% of new allocations to alternative investments be made to firms owned by minorities, females or persons with a disability (MFDB). This goal is reviewed annually and presented to the Board as a component of the Investment Policy, most recently at the September 11, 2015 Board meeting.

V. Minimum Qualifications: The Proposer must meet all of the following minimum qualifications to be given further consideration. Failure to satisfy any of these qualifications and requirements upon submittal of the Proposal will result in the rejection of the Proposal. The Proposer must certify in writing on the Minimum Qualifications Certification, Appendix A, that it meets all of the minimum qualifications. Such certification must include evidence of how each qualification is met and must be signed by an individual who is authorized to bind the Proposer contractually. Qualified firms meeting the Illinois statutory definition of “Minority owned business”, “Female owned business” or “Business owned by a person with a disability” are exempt from (6), (7), and (8) below and will be evaluated for further consideration at SURS’ discretion.

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1. Proposing firm must be SEC-registered or exempt from registration with the nature of the exemption provided. The firm must submit its full Form ADV (Parts I and II).

2. Proposing firm must agree to serve as a “fiduciary” to the Fund within the meaning of Illinois legislation and to act in accordance with all requirements and standards of conduct applicable to fiduciaries.

3. Proposer and its proposed team have all authorizations, permits, licenses and certifications required by federal and state laws and regulations to perform the services specified in this RFP at the time Proposer submits a response to the RFP. Proposer’s audited financial statements must be made available for review.

4. Proposer will comply with all legislation regarding investment restrictions, applicable State fiduciary, ethics, and diversity laws, including any additional disclosure requirements as outlined above.

5. Proposer must provide net fund-level performance track record of the proposed strategy for the RFP as well as underlying holdings information in the provided template.

6. Proposer or one or more principals of the firm must have three years or more experience managing private equity fund-of-funds portfolios with exposure to emerging2 managers. Qualified Women, Minority, or Disabled Owned Businesses are exempt and will be evaluated for further consideration at SURS’ discretion.

7. Minimum Firm Level AUM: $1 billion as of 6/30/15. Qualified Women, Minority, or Disabled Owned Businesses are exempt and will be evaluated for further consideration at SURS’ discretion.

8. Proposing firms must have been in operation as an investment management organization for at least four years, as of June 30, 2015. Qualified Women, Minority, or Disabled Owned Businesses are exempt and will be evaluated for further consideration at SURS’ discretion.

SURS retains the sole right to decide whether any Proposer is qualified to bid, including determining whether any Proposer’s qualifications are sufficiently comparable to satisfy all of the above minimum qualifications.

VI. RFP Specifications:If, in response to this RFP, trade secrets or commercial or financial information are furnished under a claim that they are proprietary, privileged or confidential and that disclosure of the trade secrets or commercial or financial information would cause competitive harm to the person or business, such claim must be clearly made and such information must be clearly identified.   The information must be identified in the   RFP response and provided separately   from the remainder of the   RFP response.   Such a claim is not definitive.  SURS has the right and obligation to determine whether such information is exempt from disclosure under the Illinois Freedom of Information Act (5 ILCS 140/7 and 7.5).  However, no information will be determined to be proprietary, privileged or confidential unless it is identified and separated as indicated herein. 

2 40 ILCS 5/1-109.1(4) defines “emerging investment manager” to mean "a qualified investment adviser that manages an investment portfolio of at least $10,000,000 but less than $10,000,000,000 and is a ‘minority owned business’, ‘female owned business’ or ‘business owned by a person with a disability’ as those terms are defined in the Business Enterprise for Minorities, Females, and Persons with Disabilities Act.”

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Specific Items Requested from Respondent Firms:Enumerated below are the specific items requested from respondent firms.

1. Letter of Transmittal . A letter of transmittal must be submitted on the Proposer’s official letterhead. The letter must identify all documents provided collectively as a response to the RFP, and must be signed by an individual authorized to bind the Proposer contractually. An unsigned proposal will be rejected. The letter must also contain the following:

a. Statement that the proposal is being made without fraud or collusion; that the Proposer has not offered or received any finder’s fees, inducements or any other form of remuneration, monetary or non-monetary, from any individual or entity relating to the RFP.

b. Statement that discloses any current business relationship or any current negotiations for prospective business with the Board or any SURS Board Members or SURS Staff.

c. Statement that the proposing firm has been in compliance with the System’s Quiet Period Policy and Ex-Parte Communications Policy.

2. Minimum Qualification Certification . The Proposer must complete the certification in Appendix A and provide all supporting documentation.

3. Diversity Disclosures per Illinois Pension Code Section 1-113.21 . The Proposer must complete the required disclosures regarding staff and vendor diversity in the form provided in Appendix B.

4. Questionnaires and Associated Excel Data . The Proposer must address the questionnaire items in the RFP in the order in which they appear in the RFP. Further, each question number and question in the RFP shall be repeated in its entirety before stating the answer. Certain questions may require supporting documentation, which should be submitted as attachments to the questionnaire. Specifically, Proposers should complete the RFP based on proposed strategy:

a. Appendix C – SURS Questionnaire and Price Sheet (Word document)b. Appendix D – NEPC Questionnaire (Word document)c. Appendix E – NEPC Questionnaire – Fund Level Performance (Excel document)d. Appendix F – NEPC Questionnaire – Fund Cash Flows (Excel document)e. Appendix G – NEPC Questionnaire – Deal-by-Deal Track Record (Excel document)f. Appendix H – Employee Diversity Chart (Excel document)

Proposers who fail to complete each Attachment in its entirety will not be considered.

Submission Deadline:The completed RFP must be delivered (electronically, please) by 4:30 pm CT, Monday, December 14, 2015. Earlier responses are welcome. Any RFP delivered after the deadline will not be considered. The e‐mail subject line must read as follows: “Private Equity Emerging Manager RFP Response – Name of Respondent” and should be sent to both SURS and NEPC at:

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Kim Pollitt, CFA Bradley Rowbotham, CAIASURS NEPCSenior Investment Officer Research Analyst, Private Marketsinvest@surs.org browbotham@nepc.com

Submission of Questions:In order to clarify any issues in this Request for Proposals, the System will respond only to questions that are presented in writing via e-mail to: Kim Pollitt, CFA, at invest@surs.org. All questions should be submitted to SURS by 4:30 PM CT Monday, November 30, 2015. These questions will be consolidated into a single Q&A document and responded to by the System on, or about, Monday, December 7, 2015. The Q&A document will be posted on the SURS web site at www.surs.org /rfp without divulging the source of the query.

Communications with SURSOther than existing normal business matters, respondents, potential respondents, or their representatives should not contact anyone at SURS (including SURS staff, members of the SURS advisory committees and members of the SURS Board) other than the investment team assigned to the RFP listed above.

In addition, respondents must not discuss this RFP with any employee of SURS’s custodian, managers, legal counsel, or other advisors or persons/entities having contracts or other affiliations with SURS.

FAILURE TO OBSERVE THIS RULE IS GROUNDS FOR DISQUALIFICATION

SURS Quiet Period Policy:Please note the Quiet Period Policy that establishes guidelines by which the Board of Trustees and staff will communicate with prospective service providers during a search process. Please review Section VIII of the Investment Policy and observe the Quiet Period guidelines. The Quiet Period for this search was initiated on June 12, 2015.

Ex-parte Communications:The State Officials and Employees Ethics Act (5 ILCS 430/5-50) provides that all “ex parte communications” concerning investment, rulemaking or quasi-adjudicatory matters pending before a State agency must be documented and some must be reported. An “ex parte communication” is any written or oral communication by any person that imparts or requests material information or makes a material argument regarding potential action concerning an investment, a rulemaking process, or a quasi-adjudicatory matter. An “ex parte communication” does not include statements publicly made in a public forum or communications among employees of the State agency.

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An “ex parte communication” from an “interested party” or his or her official representative or attorney to an employee or the agency must be memorialized and made a part of the record. An “interested party” is a person or entity whose rights, privileges, or interests are the subject of or are directly affected by an investment, regulatory or quasi-adjudicatory matter.

An “ex parte communication” other than that described above must be reported by the staff member or Board Trustee immediately to the agency’s Ethics Officer. The communication must be memorialized and made a part of the record. The communication must be filed with the Executive Ethics Commission, accompanied by a memorandum from the Ethics Officer.

Rights Reserved:SURS reserves the right to amend any segment of the RFP prior to the announcement of a successful contractor. In such an event, all responders will be afforded the opportunity to revise their proposal to accommodate the RFP amendment.

SURS reserves the right without prejudice to reject any or all proposals submitted. The System is not obligated to award a contract to any of the respondents to this RFP. There is no express or implied obligation for SURS to reimburse for any expenses incurred in preparing proposals in response to this RFP.

VII. Projected Schedule of Events:June 12, 2015 Quiet period beginsNovember 16, 2015 Dissemination of RFPNovember 30, 2015 Deadline for questions to SURSDecember 7, 2015 Responses to questions submitted to SURSDecember 14, 2015 RFP responses due by 4:30 pm CTJanuary/February 2016 Identify firms for further considerationFebruary 2016 Interviews with selected firmsMarch 10, 2016 Finalist presentations to SURS Board of Trustees

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Appendix A

MINIMUM QUALIFICATION REQUIREMENTS AND CERTIFICATION

Proposers must satisfy each of the following minimum qualifications for this RFP, in order to be given further consideration by the Board of Trustees. Failure to satisfy each of the requirements will result in the immediate rejection of the proposal. Failure to provide complete information will result in the rejection of the proposal. Please circle “YES” or “NO” where indicated. If evidence is requested, please provide complete documentation.

1. Proposing firm must be SEC-registered or exempt from registration with the nature of the exemption provided. If so registered, please submit Form ADV (Parts I and II). (Yes/No):_____

2. Proposing firm must agree to serve as a “fiduciary” to the Fund within the meaning of Illinois legislation and to act in accordance with all requirements and standards of conduct applicable to fiduciaries. (Yes/No):_____

3. Proposer and its proposed team have all authorizations, permits, licenses and certifications required by federal and state laws and regulations to perform the services specified in this RFP at the time Proposer submits a response to the RFP. Proposer’s audited financial statements will be made available for review. (Yes/No):_______

4. Proposer will comply with all legislation regarding investment restrictions, applicable State fiduciary, ethics, and diversity laws, including any additional disclosure requirements. (Yes/No):_______

5. Proposer must provide net fund-level performance track record of the proposed strategy for the RFP as well as underlying holdings information in the provided template. (Yes/No):______

6. Proposer or one or more principals of the firm have three years or more experience managing private equity fund-of-funds portfolios with exposure to emerging3 managers. Qualified Women, Minority, or Disabled Owned Businesses are exempt. (Yes/No/Exempt):______

7. Proposer must have at least $1 billion in institutional (taxable and non-taxable) assets under management, as of June 30, 2015. Qualified Women, Minority, or Disabled Owned Businesses are exempt. (Yes/No/Exempt):______

8. Proposing firms must have been in operation as an investment management organization for at least four years, as of June 30, 2015. Qualified Women, Minority, or Disabled Owned Businesses are exempt. (Yes/No/Exempt):______

IF PROPOSER PROVIDED A “NO” RESPONSE TO ANY OF THE MINIMUM QUALIFICATION REQUIREMENTS ABOVE, PROPOSER SHOULD NOT SUBMIT A PROPOSAL TO SURS.

3 40 ILCS 5/1-109.1(4) defines “emerging investment manager” to mean "a qualified investment adviser that manages an investment portfolio of at least $10,000,000 but less than $10,000,000,000 and is a ‘minority owned business’, ‘female owned business’ or ‘business owned by a person with a disability’ as those terms are defined in the Business Enterprise for Minorities, Females, and Persons with Disabilities Act.”

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PLEASE CERTIFY THE PROPOSER’S SATISFACTION OF THE MINIMUMQUALIFICATIONS BY PROVIDING THE PROPOSER’S AUTHORIZED SIGNATUREBELOW.

Authorized Signer Name: ________________________________Title: ________________________________Respondent Firm: ________________________________Signature: ________________________________Date: _______________________________

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Appendix B

DISCLOSURES PER ILLINOIS PENSION CODE SECTION 1-113.21

Beginning January 1, 2015, section 1-113.21 of the Illinois Pension Code requires the following disclosure from the investment advisor, consultant or private market fund:

Name of investment advisor, consultant, or private market fund:

________________________________________________________________________

1. The number of its investment and senior staff and the percentage of its investment and senior staff who are (i) a minority person (ii) a female, and (iii) a person with a disability;

(If none, state “none”)

Staff Classification Number of Investment and Senior Staff Who Are

% Percentage of Investment and Senior Staff Who Are

MinorityFemalePerson with a Disability

2. The number of contracts, oral or written, for investment services, consulting services and professional and artistic services that the investment advisor, consultant, or private market fund has with (i) a minority owned business, (ii) a female owned business, or (iii) a business owned by a person with a disability; and

(If none, state “none”)

Contracts Number ContractsMinorityFemalePerson with a Disability

3. The number of contracts, oral or written, for investment services, consulting services, and professional and artistic services the investment advisor, consultant, or private market fund has with a business other than (i) a minority owned business, (ii) a female owned business or (iii) a business owned by a person with a disability, if more than 50% of services performed pursuant to the contract are performed by (i) a minority person, (ii) a female, and (iii) a person with a disability.

(If none, state “none”)

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Contract Number ContractsMinorityFemalePerson with a Disability

Supplemental Information (Optional):If desired, please include additional information on your firm’s diversity efforts to supplement the information provided above. This may include initiatives such as internal training and development programs, as well as recruitment and outreach efforts, etc.

INVESTMENT ADVISOR / CONSULTANT/ PRIVATE MARKET FUND:

Company Name:

Signature:

Printed Name

Title:

Dated:

Resources and DefinitionsSection 1-113.21 of the Illinois Pension Code website: http://www.ilga.gov/legislation/publicacts/98/PDF/098-1022.pdf

Definitions per Illinois LawIllinois Legislation & Laws website: http://www.ilga.gov/

"Contract" means all types of [State] agreements, regardless of what they may be called, for the procurement, use, or disposal of supplies, services, professional or artistic services, or construction or for leases of real property where the [State] is the lessee, or capital improvements, and including renewals, master contracts, contracts for financing through use of installment or lease-purchase arrangements, renegotiated contracts, amendments to contracts, and change orders.

 “Investment adviser”, "investment advisor", or "investment manager" with respect to a pension fund or retirement system established under Illinois Code if the person:        (1) is a fiduciary appointed by the board of trustees of the pension fund or retirement system in accordance with Section 1-109.1;        (2) has the power to manage, acquire, or dispose of any asset of the retirement system or pension fund;        (3) has acknowledged in writing that he or she is a fiduciary with respect to the pension fund or retirement system; and        (4) is at least one of the following: (i) registered as an investment adviser under the federal Investment Advisers Act of 1940 (15 U.S.C. 80b-1, et seq.); (ii) registered as an investment

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adviser under the Illinois Securities Law of 1953; (iii) a bank, as defined in the Investment Advisers Act of 1940; or (iv) an insurance company authorized to transact business in this State.

“Minority person” means a person who is a citizen or lawful permanent resident of the United States and who is a member of a minority.

"Minority owned business" means a business concern which is at least 51% owned by one or more minority persons, or in the case of a corporation, at least 51% of the stock in which is owned by one or more minority persons; and the management and daily business operations of which are controlled by one or more of the minority individuals who own it.

"Female owned business" means a business concern which is at least 51% owned by one or more females, or, in the case of a corporation, at least 51% of the stock in which is owned by one or more females; and the management and daily business operations of which are controlled by one or more of the females who own it.

"Business owned by a person with a disability" means a business concern that is at least 51% owned by one or more persons with a disability and the management and daily business operations of which are controlled by one or more of the persons with disabilities who own it. A not-for-profit agency for persons with disabilities that is exempt from taxation under Section 501 of the Internal Revenue Code of 1986 is also considered a "business owned by a person with a disability".

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