Okay this is kind of fun actually making the cards, especially stealing the research and ideas from the old forum.
Again from Zerstorer:
Tanks with rapid fire light guns (panzer 2) or guns up to around 50mm short get 3 attack dice. Obsolete guns (37mm short as in the FT-17 or the R35) get 2 attack dice. MG armed tanks get 2 attack dice. You might consider not allowing them to score critical hits, but we have not felt the need to do that. 2 attack dice sucks enough. Most early war tanks are armor 0 with very few hit points. French tanks and some Russian tanks are an exception, either armor 1 with lots of hits (Char B1, KV-1, KV-2; heavy tanks, but slow as well) or armor 0 with a higher number of hits than others. For the French, iirc I used formidable for their national trait and this allows them to ignore their first crew casualty, shell shocked or stunned crew result (thanks for suggestions on this gang!).
Don’t make your points costs by taking a mid or late tank and extrapolating down. If you do, the early war tanks are way too cheap. Kind of figure that the cheapest tank is 8 pts and work up from there.
Isn’t a Panzer III short 11 pts? Up-armored 38t’s are about equal to a Panzer III short. I have been running early 38t’s as 4-3-1-3, 10 points. Armor 1is generous, but only 3 hit points seems to make them brittle enough.
So I used the stats directly for the 38(t), and Panzer II I gave zero armor but went with recon. I figure it has a small profile so in cover it could hide better. With that I thought 9 points might be about right.
Mostly I made these because I want to test out against my T-35 and going with the early war theme. Hopefully I can play test later and see how close German numbers and tactics do against some huge Russians.
Oh, and these for real had 3 crew, for the cards, should I make them only 2 crew slots or is having 3 fine?
You got there first, I was in the process of getting the 38(t), but great job! 
Yes it is fun, especially for a Friday evening. With regards to crew, keep 3 I suggest. Reserve two to tankettes.