I think that would be an interesting idea. I like to have a "conscript focus" loadout in which all the commanders include con repair, and 2 of the three have assault package. I don't think it would be that OP because A.) Penals would bleed more on the approach because they have no way to get close quickly (no oorah) B.) Much more expensive than cons. and C.) they have no snare/ antitank capabilities once upgraded with ppsh (PTRS patched out of PPSH penals long ago).
Infact, considering all these things, I would just use conscripts to supplement penals if I went for a penal build anyways lol.
I was thinking the same thing, Penals would be powerful but expensive in cost and reinforce however with certain commanders it would give 2 possible openings. With Guards Rifle Combined, I was thinking hard hitting slow early game that is helped with Guards Rifle to fight back against LV. An M5 could be used to keep up mid game pressure while stalling for the KV1. The other commander was Soviet Reserve, it would work similar to Airborne for USF where both tech are "covered". The main draw back would be how MP intensive it would be around mid game. However you get mg and AT along with PPSH Penals.