I fail to see how PTRS Penals overlap with guards anymore than half the other Commander call in units.
There is no reason to get guards anymore. Penals cover their role perfectly with even more functionality (apart from a grenade and lmg, but that is offset with flamethrower ppsh package, molotovs, a satchell that is both at and ai).
You can quite easily get penals, move into dhsk call in hmg and then get a T70 and stall your way into multiple m4c sherman call ins.
I can see your thoughts behind the acts of these balance changes and I think the intentions are well meant. But it won't change anything, since you can now crutch your way with penals to your call in units, which most likely will be dhsks and m4c shermans, because they offer perfect synergy. This strat in combination with maxim spam will be Soviet meta if the patch hits with the current balance mod aspects in place.