The current study aimed to test a Relational Frame Theory (RFT) model of analogical reasoning based on the relating of derived same and derived difference relations. Experiment 1 recorded reaction time measures of similar–similar (e.g., “apple is to orange as dog is to cat”) versus different–different (e.g., “he is to his brother as chalk is to cheese”) derived relational responding, in both speed-contingent and speed-noncontingent conditions. Experiment 2 examined the event-related potentials (ERPs) associated with these two response patterns. Both experiments showed similar–similar responding to be significantly faster than different–different responding. Experiment 2 revealed significant differences between the waveforms of the two response patterns in the left-hemispheric prefrontal regions; different–different waveforms were significantly more negative than similar–similar waveforms. The behavioral and neurophysiological data support the RFT prediction that, all things being equal, similar–similar responding is relationally “simpler” than, and functionally distinct from, different–different analogical responding. The ERP data were fully consistent with findings in the neurocognitive literature on analogy. These findings strengthen the validity of the RFT model of analogical reasoning and supplement the behavior-analytic approach to analogy based on the relating of derived relations.