In his article "THE INDEPENDENCE OF THE CONTINUUM HYPOTHESIS", Paul Cohen writes in the beginning:
We shall work with the usual axioms for Zermelo-Fraenkel set theory, and by Z-F we shall denote these axioms without the Axiom of Choice, (but with the Axiom of Regularity).
Thus the meta-theory he is working in is the Zermelo-Fraenkel set theory without AC, but with the axiom of regularity. In this meta-theory, Cohen proves his famous result that CH is indepedent of ZFC. Now I wonder:
Did he use the regularity axiom of his meta-theory in his proof?
If he did use Regularity in some of the argument, then he still didn't have to, because he could just have carried out everything relative to WF, the class of hereditarily well-founded set. WF satisfies ZF with Regularity even if the ambient universe does not satisfy Regularity.
Becuase the consistency of this theory or that is just a matter of arithmetic (thanks to Gödel) and $\omega$ is the same within WF as outside it, this would lift any relative consistency result from WF to a weaker meatheory.