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I think the character is good, I like the story a lot. I calculated around 75 points for the commander
(5 for +1BS, 5 for+1 Ld, 15 for improving order range, 15 for weapon (4 Rending attacs while assaulting and 2 str 4 shots), 10 for outflank, 10 for COs modifying Ld, 15 for stubborn 12" bubble and 5 for Preferred enemy)
I'm not familiar with Tyranid codex, which I assume this is to be fielded against, so can't really tell how effective he might be.
Overall, I like it
Rules issues I saw: Cultivator of free Thought doesn't allow for comissars of either standing. I assume this is intentional as comissars aren't known for allowing thinking, free or otherwise, as that would most likely distract from actual fighting. Ld 9 with this rule and stubborn means that I cant fail a Ld test, which might make this a bit too powerful. Put in a banner for reroll and you need to roll a 12 twice in a row to fail a Ld test.
On using I instead of Ld: Why? at I3 i get 50% chance of success, with Ld 7 I get 66%. As I said, I don't know if t'nids have some way of reducing Ld, but if they don't, this option is largely useless.
I'd make bodyguards 10 or 15 in addition to the normal upgrade.
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