I remember read that H-35 receive in early 1940 the improved 37mm gun like the one used in H-39 and i imagine this is the situation, maybe change the portrait name in a similar way used to diference between PzIII with L60 VS L42...
Yep, the SA is very powerfull in game looks a mistake like the problem with 76mm arty for Luftwaffe land divisions in Normandy.
I did some modding before go bed and i find something strange, i prefer have german army in grey and SS in black and i use the files from Normandy but i find that in the unit portrait not all have the icon in the correct colour.. for example here you see one in grey and other in the old blue colour, same with SS where some appear in black and other in grey. I dont know how is possible because in Normandy and Kursk same type of modding change to the new colour the unit portrait NATO symbol
http://i.imgur.com/G1btuxb.jpg