no it is not...
no player should immediately select commanders at the beginning of the game. Once you see a fast FHQ, OKW should get a Stuka and Ostheer should get a mortar halftrack. These units counter the FHQ well. If you don't have any of those, then is suggest locking the area down with mortars and mgs. It also costs 60 fuel, so the SOviet player will be using manpower-only units for a while
I know it's expensive and it is no less useful if a territory is required to be captured/owned first before it can be placed. This stops abusive players rushing their infantry to the forward most buildings and shutting down a game before it can even begin. We are talking about within the first 2-3 minutes and the game can be over.
It's not always as simple as "just us MG's and Mortars" because there are also plenty of cheese strats that compliment this abusive ability. Sniper Spam, Con Spam, Vanilla American Rifles become instant elite infantry just by being near the damn thing due to its bonuses. A single prerequisite of owning the territory isn't all that much to ask and it is a welcome delay that would buy German players enough time to also establish a territory to compete.