I would argue the even deeper problem is that it's implementation defined. Should be in the spec and they should conform to the spec. That's why I'm so paranoid and zeroize things myself. Too much hassle to remember what is or isn't zero.

I wouldn't depend on that too much either though, or at least not depend on padding bytes being zeroed. The compiler is free to replace the memset call with code that only zeroes the struct members, but leaves junk in the padding bytes (and the same is true when copying/assigning a struct).