Glass, Lewis & Co. is the second largest proxy advisory firm and is an indirect wholly owned subsidiary of the Ontario Teachers’ Pension Plan Board, one of Canada’s largest pension systems. According to the Mercatus Center, Glass Lewis currently maintains approximately 37% of the market share for proxy advisory services. Glass Lewis provides proxy research, an electronic proxy voting platform, analysis of shareholder proposals and engagement support. Unlike ISS, Glass Lewis does not provide consulting services to issuers. However, Glass Lewis has been criticized for a lack of transparency. In 2012, the firm made certain changes in light of that criticism, including holding meetings with issuers outside of proxy season, and establishing an "issuer engagement portal. Glass Lewis also announced the beginning of a partnership with Equilar. As part of the partnership, Glass Lewis now incorporates Equilar data as the basis for its pay for performance analysis, including Equilar’s market-based peer group methodology and its realizable pay calculation. In addition, Equilar clients are able to run simulations of the Glass Lewis pay for performance test under various “what if” scenarios and obtain their Glass Lewis report. The Center will continue to engage with Glass Lewis to encourage it to adopt and apply policies in a practical, board centric manner.