For the total point cost and tax of a kempei there are better choices. I like oniwaban and am definitely coming around to kempei back ups for an aggressive lt but better choices for my play as an lt. Having said that I do take the lady killer shinobu as my lt against certain armies. The new list gives a lot better kempei load outs too so I may be old school in my thinking right now. I also face a lot of those pano lvl 3 visors in my area.
I feel like the 21 point Kempeitai is just an auto-include in every list anyway. Every JSA lieutenant is aggressive except the Keisotsu and he costs 1SWC in an army that now really wants every point of it. And the order you lose for taking a kempei over 2 Keisotsu you make up for with the lieutenant order you can use more safely.
On the original question I would never ever find myself running out of points before SWC in the Japanese Sec- er... S. Army.
Well it used to be a linked sixth sense Neko lieutenant didn't need a Kempetei back up because he was so difficult to kill. No Speculo or Fiday was gonna close combat him, and burst 2 PHYS 17 grenades out-shot back at impersonating or AD shotguns. Two wounds and Phys 14 dodge meant he had a better chance of surviving a turn of heavy grenade launcher bombing than he did of dying. But now that he's so vulnerable to Druze X visor E/M grenade launcher shenanigans I'm not sure you can take him without a kempetei anymore. I just don't know how many orders it will generally take for a BS 9 grenade to hit against his PHYS 14 dodge. Any fewer than eight and you'd better have a kempetei. At least now I know a Kempetei *will* work against e/m though!
Well, IMO the important question isn't so much "Did I spend all my SWC" but "Do I have a bunch of weapons that have range bands other than the basic combi rifle". And you have that covered. Let me give you the general list-building advice I give all new players. There are 4 things that make a good army: Orders. You want at least 8 regular orders in your primary combat group at the start of your first turn. So not more than two Airborne or Hidden Deployment troops per combat group. Note that you don't have to deploy TO camo Ninjas or Oniwaban Hidden, you can deploy them on the field as a marker and use their order from word go. Guns. This isn't "Did I spend all my SWC", this is "Do I have different range bands covered with a +3 somewhere in the army?" Mk12s don't usually cost SWC for example, but they count for 'Guns' (since they have almost the same range bands as a Marksmans Rifle). Speed. This is also a bit deceptive. I'm not just talking about models with an 8-6 or 6-4 movement, I'm talking about anything that has to spend the minimum amount of orders to get to where you need it. So infiltration, Airborne Deployment, Forward Deployment, Mechanized Deployment, plus the obvious Motorcycles and REMs. If that missile launcher will be in +3 range if it steps out of cover, use it for the shot instead of spending 4 orders to get a Domaru there to CC the target. This is most critical when you're playing Limited Insertion, with a max of 10 models in the combat group! Link teams can kinda fall under speed, even though most are only 4-4 move and start in your Deployment Zone, since they get a number of models upfield with a minimum number of orders. Specialists. These are the guys who will win you the game. I recommend bringing at least 4: Forward Observer, Doctor, Engineer, and usually hacker. There are other specialists in the game, like the Kempeitai's Chain of Command. If you are running more than one Heavy Infantry, I recommend a basic hacker. If you are running an Assault Hacker like the Aragoto, I'd strongly recommend a Ninja Killer Hacker, too. The killer hacker's job is to kill anyone trying to killer hack your assault hacker. Note that these are not restrictive categories, a lot of models count for two different options. For example, a Kempeitai Chain of Command w boarding shotgun is both a specialist and a gun (due to that +6 within 8"). An Aragoto hacker is a fast specialist, as is a Ninja hacker or FO.