Against OKW I would say move your m3 up 1 unit so it goes penal m3 penal penal tech. You want as much time with the clown car as you can get since OKW has no fausts early. Faster flamer engineers in the clown car the better as well.
Against OST I personally abandon penals and go conscripts since they trade well enough with grens early and get the 7 man upgrade later. I find penals are a bit awkward vs grens since their high damage rifles often pick a model before penals can close to mid which really hampers their high cost DPS. Plus the LMGs later really punish penals.
I'd say diversify by building a maxim to support penals. They may be subpar now but are getting a slight buff in the mod. Futhermore if you want different commanders try some shock rifle or armored assualt(?). The one with 34/85s, radio intercept and IS2. Shock rifle gives you the very strong shock troopers which complement the mid/long range of penals very nicely, and the PTRS penals cover the shock troopers with AT. IS2 currently is a very nice tank and if the mod were to go live right now, the IS2 would be king of the new meta. Although new changes coming up so may want to look out for that.
Hope this helped a bit. Strafniki made some good points as well
