A semitone at 440 = +-26.16 Hz
1/64 = 26.16/32 = +-0.8175 Hz
So i guess the question is: Are 0.8175 Hz differences close to limitations of PCM at a normal 48 KHz sample rate for reasonable tone lengths? 48000/440 = 109.0909090909091
48000/440.8175 = 108.88859902340538
So for 440 Hz there are either 109 or 110 points per sinusoid, averaging 109.09. For 440.8175 Hz there are either 108 or 109 points per sinusoid averaging 108.88Although the true sinusoid doesn't start and end at exactly on those points, this is how many points "land" on each period. There are also subtle differences in the amplitude of each point on different periods with the same number of points - i'm not sure how to rate that in terms of perception but my suspicion is that we are affected more by the average period, by using the highest/lowest points (half a period).
If true, the duration becomes very important, 108 periods fit into 1 second, which gives us a max precision of 1/108 = about 0.93% i.e +-1.013 Hz error... which is larger than the difference we are trying to detect.
I'm not confident in these calculations, but It does at least seem very close to the precision limit of 48KHz... So I'm guessing the starting position of the modulation has quite an influence on which way that error swings, and this could account for the differences we are hearing between +1/64 and -1/64
</ hand waving>