The frequency following response (FFR) arises from the sustained neural activity of a population of neurons that are phase locked to periodic acoustic stimuli. Determining the source of the FFR noninvasively may be useful for understanding the function of phase locking in the auditory pathway to the temporal envelope and fine structure of sounds. The current study compared the FFR recorded with a horizontally aligned (mastoid-to-mastoid) electrode montage and a vertically aligned (forehead-to-neck) electrode montage. Unlike previous studies, envelope and fine structure latencies were derived simultaneously from the same narrowband stimuli to minimize differences in cochlear delay. Stimuli were five amplitude-modulated tones centered at 576 Hz, each with a different modulation rate, resulting in different side-band frequencies across stimulus conditions. Changes in response phase across modulation frequency and side-band frequency (group delay) were used to determine the latency of the FFR reflecting phase locking to the envelope and temporal fine structure, respectively. For the FFR reflecting phase locking to the temporal fine structure, the horizontal montage had a shorter group delay than the vertical montage, suggesting an earlier generation source within the auditory pathway. For the FFR reflecting phase locking to the envelope, group delay was longer than that for the fine structure FFR, and no significant difference in group delay was found between montages. However, it is possible that multiple sources of FFR (including the cochlear microphonic) were recorded by each montage, complicating interpretations of the group delay.