Research review boards, established to protect the rights and welfare of hu
man research subjects, have to ensure that conflicts of interest do not int
erfere with the ethical conduct of medical research. Private, commercial re
view boards, which increasingly review research protocols, are themselves a
ffected by a structural conflict of interest. Within the regulatory setting
, procedural conflict-of-interest rules research review and the reliance on
the fairness and good judgment of institutional review board members. Curr
ent guidelines and regulations lack adequate conflict-of-interest rules and
provide insufficient details on the substantive rules. Because commercial
review boards are similar to administrative courts and tribunals, rules of
administrative law on bias are applied to determine when a conflict of inte
rest jeopardizes the purposes of research review; administrative law has al
ways judged financial conflicts of interest severely. The structure of priv
ate review tends to breach a core principle of administrative law and proce
dural justice. Reform of research review system will reinforce public trust
in the process.