That's certainly not the case because TiVos don't tune analog at all (and I know that for a fact)
You should then also know that was a waiver that the FCC specifically made ONLY for Tivo:
http://www.multichannel.com/news/policy/fcc-grants-tivo-waiver-analog-tuner-mandate/262828
In addition, there is already a TV set analog tuner mandate still in place, which means any set a TiVo is connected to can display analog broadcast or cable channels, the FCC pointed out in granting the waiver.