The problem is that the M3 has trouble effectively fulfilling its role as a counter to Ostheer infantry without AT, especially p-grens and to an extent assault grenadiers, LMG grens and even MG-42s. This is exacerbated by the way some bugfixes have made it far easier for the Ostheer to counter. Vet is the problem with the 221; not the problem with the M3.
Right now the 221 armoured car (and the 222) is a phenomenally cost-effective unit for any player with acceptable micro. The M3, not so much. Speeds are identical, I think.
I agree that the M3 may slightly struggle but I think this is primarily due to the way people use them. People need to understand that putting a flame thrower unit inside of the car and drive close to the enemy is a huge risk. This risk can and often does pay off, of course but people need to understand that it isn't the right thing to do in every situation.
I'm sure that when used in conjunction with other units, it does fine: As has been stated in this thread, its DPS is very comparable to the 221's DPS, it costs less etc.
The only reason it has fallen out of FotM is because the SdKfz 222's auto cannon hard counters it and because the buff of AT grenades and the Panzerfaust means the scout cars can no longer luckily survive two of those and will also die faster because it will require nearly 20 shots less to finish it with carbines. However, with guards in it the M3 counters the 222 in itself. So people going T1 will always either have to get guards or have lots of AT grenades around (with a good synergy to Oorah!).
This is the tradeoff you take when going T1: T2 offers staying power and field presence whereas T1 offers high shock potential (M3 flamer, satchel throw) and units that can deal a lot of damage but also need baby sitting (all T1 units).
Considering the M3 should never be hit by a Panzerfaust when used defensively and carefully -like a 221 scout car usually is- its stats and cost are very similar to the 221's stats while also offering additional power/features. The lower fuel cost may be accounted to the cost of the Soviet T1 building and the higher versatility of German T2.
However, I'm still rather curious what and how they change it and I think small changes like a slight armor increase won't make it overpowered in the manner it was a few months back.
I just don't want to see a return to the clown car days (see that comic guy's comic for that).