Now that I think about it, that makes perfect sense, because since the VDC chip in the C128 has composite output, it would have to scan at 50Hz to be compatible with PAL displays. And thus PAL-region 1902 monitors also scan at 50Hz and are incompatible with CGA.
The C128 has 4-bit RGB just like CGA. It follows that 4-bit RGB should always produce the same 16 colors, which includes dark yellow. According to this site, the C128 does indeed produce that color and not brown:
http://john.seikdel.net/vdcmadeeasy01.htm
It also says that most monitors will produce brown, however I assume that only ones designed for PCs do that (ie. clones of the 5153). Monitors such as the NEC Color Character Display and the Commodore 1902 that were intended for non-PC machines should display yellow.
That would be the maximum scan line register, correct?