I would move the KE7 level three Japanese mg to level two, especially if what people I know that play above level two Japan tell me is correct, that no one plays level three Japan. 
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KE7 on BR II would be fair! At least for the pacific, the german MG13 maybe need a “buff” (or just fix the stupid DiSpErSiOn, such an unrealistic crap) and it should be fine to place the BAR1918 at BR II. The BAR should get a dispersion fix too (0.65 is ridiculous good).
US players would still be faster with that machine gun, but germany/italy has other strengths to compensate that.
I would certainly agree with you on this. I play Germany far more now then I do any other faction, and like with the BAR A2 in my level three Allies, sometimes I use three MG squads in my level two Germans, and have two MG13’s in my APC’s as well, so, I get a lot of use with the MG 13.
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