It depends, or course on where he is and what code cycles and amendments are in effect.
For example, the City of Spokane, while referring to the IRC and Washington State Energy Code.
states in a
summary concerning additions and remodels That implies to me that the absolute fan requirement applies to entirely new construction as well. I am still looking for the ultimate source of that though.
The 2012 IRC does not appear to require that, and I have not found anything newer.
Similarly the
2013 California Green Building Standards Code contains the following:
This is not an optional Green certification code but rather a mandatory code for all state regulated buildings (Feds are exempt!) and specifically includes:
It is effective Jan 1, 2014 so it might be the sort of thing the OP heard about.