I'm wondering why that doesn't apply here. The TPM holds the key to the cipher that is protecting your private keys. Someone uses some kind of RCE or LPE to get privileged access to your system. Now it sits and waits for you to do something that requires access to your SSH keys. When you do that you are expecting whatever user prompts come up, the malware rides along this expectation and gets ahold of your private SSH keys and stores them or sends them off somewhere. I'm not even positive that they need high degree of privileges on your box, if they can manipulate your invocation of the ssh client, by modifying your PATH or adding an ssh wrapper to something already in your path, then this pattern will also work.
What am I gaining from using this method that I don't get from using a password on my ssh private key?