The British named Locust and got more use out of it than the Americans, arguably it should be Researchable in both TTs. A captured or Egyptian Locust could be added to Israel, if their low-tier is ever added.
Same thing as vehicles like the Chieftain MK10. Only the good players play mediocre tanks, and make the stats inflate to levels that aren’t accurate. So they get moved up, and that just makes the problem worse.
“Armor” - KV-1 at 3.7 can lolpen its lower plate. Not to mention every early long-barreled Panzer IV at 3.3-4.0 also exists.
“firerate” - It’s a 2-pounder at 3.3. It doesn’t have “Decent” ammunition. It can’t even kill a KV-1 anywhere and can see 4.3. At best, you’re squeezing out 89mm of penetration on a 40mm in a tank that moves as slowly as super heavies while fighting the best versions of the Panzer IV. Even the Sherman’s 75mm APHE can struggle against the Panzer IV with track armor, so what do you really expect a Churchill with a 40mm going, at best, 28kph to do?
Not to mention that the 76mm howitzer is a gimmick while you seem to think it’s some meta protection device. Smoke Shells have never been more useful than just shooting back with a lethal round, especially when your tank moves so slowly. This Churchill, in its current state, is not a brawler. The KV-1 can’t die to it, and every 3.3 vehicle is a hard counter.