ABI is a factor in every language;* so I’m not sure I understand the point you’re trying to make.
* even interpreted ones, though the calling conventions and layout are quite different from what is typically written up in the documentation of most compiled languages.
The term "modern compiler" was used, which implies that an old compiler might (say) not do so despite complying with some ABI, i.e. the registers aren't an optimization.
I have never used a compiler that didn't allocate frames in a single move of the sp, and I've been using compilers since the 1970. Surely "modern" has to mean some change more recent than that.
* even interpreted ones, though the calling conventions and layout are quite different from what is typically written up in the documentation of most compiled languages.