I think you are wrong. The sim engine makes decisions on a "possession" basis not "action" basis. What I mean by that is when one team has the ball it decides what happens (Shot, turnover, foul) as opposed to what happens every time each individual player touches the ball.
I believe tempo merely modifies how long each possession is before a decision is made. There used to be significant, intelligent discussion on if there was a "penalty" on running up tempo but I don't think a consensus was really reached. I do not believe there is.