I was toying around with this since Para's are my favourite unit. It definitely feels like you're playing one of the early WFA patches, ie. you're actively choosing to have all the flaws of the USF (no indirect fire/siege, shaky AT options) and if you want Para's this seems like a better option than the actual AB Coy
But! I digress, since you do lack the new fun tools, I found you actually have to build around the paths for the advantage you get in vision, and the only somewhat reliable artillery. This meant changing the early game capping order a little, maybe taking 2 rifles hunting trying to farm CP's and taking the economy hit, double RE's to backcap didn't work.
Do the IR paths have the snipers? 'cos they seem to hold their own in combat. They remind me of the the old Jaeger squads, particularly with vet. I wish the artillery could still delete an OKW HQ truck, as well, but maybe that's too far.
The mine drop is also more useful than I thought it was going to be, again paired with path vision, I found I could turn games against a turtling player by pushing up against my opponent ever so slightly in a counter attack, then dropping the mines just behind my opponent, either forcing him back into them, or routing his team weapons.
However, using this often (which I felt you had to, particularly in the mid/late game since you lack reliable killing power/indirect fire) + IR arty means no BAR's/Zooks, and worse, no Para upgrades.
The capture territory ability is far more useful as well than I thought at first glance. I usually go Lt, since the cmdr. overlaps well as a lazy version of T2. This means if I'm clever and preserve an M20, or actually bother with the M8, I have an ace up my sleeve for actually harassing, or I have a super tool for the close VP games. The Axis have very little they can do against this, unless they're playing a very fluid, maneuverable game from the off, which probably means they're trying to outflank you which mean's you're in the lead anyways.
Paras however... don't seem all that great :/ and that's the issue. Since this cmdr. lacks the outright killing power of the Calliope or Rifleman 30's, you're looking to Paras to provide some steel on the front line, either as shock troops or stalwart defenders and, even with the ability to reinforce in combat, they really don't hold up well enough. Rangers far exceed their performance. They melt to things like Falls, Obers-- PG's even make them think twice, even with 30cal's which, as we mention are still prohibitively expensive. Adding a .50cal helps, especially since I still don't think Axis expect to get suppressed against the USF, but the midgame with this commander is such a toil, and late game against OKW once they get Vet3 + feels like a real uphill battle, since you're always asking where your squad wipes are coming from. It seems you require your entire force to take down 2 volks.
So, in conclusion, I think you can make things work if you can get a Major and a Sherman + Jackson out in a reasonable time, but you should be doing that anyway using only the core force. This commander doesn't add anything that really stands out as being overtly useful, like Guard Motor or Lightning War, and that's too bad; but the design is solid albeit average, and I think there's a fair amount of character there.