It's happened a few times.
2000 Auburn - 40 wins
2008 Kentucky - 41 wins
2010 Vanderbilt - 40 wins
2012 Kentucky - 41 wins
Kentucky not only didn't host in 2008 with 41 regular season wins, they were a #3-seed in their regional.
There have been several other cases with SEC teams with 40+ wins after the SEC Tournament.