I don't have any punters or kickers on my team yet because my world is still recruiting (and I don't have my recruits yet) but I played an exhibition game last night. My punting stats were great. I averaged 45.7 yards on 6 punts with a long of 57 and two were downed within the 20. All 6 punts were from different players: QB, RB, TE, TE, OL, DL. My average was better than my sim opponent who was playing an actual punter.
I'm guessing out-of-position penalties are not active. Either that or I'm never recruiting another punter.