in AC, in the previous ones he was pretty low IIRC.
the thing is that a charge character is supposed to start bad, and then become good.... and since this relies on a charge system.... and they're generally a rushdown, so... the problem becomes that they have to be far away to charge, and have to be really close to fight. Not only that but HOS had ACTUAL knockdown time to charge. Tsubaki is just....bleh, charging is not really worth the risk, and her without charge sucks.... and her normals suck... she could do with HOS's action charge, or somekind of charge return on attacks... don't know too much about either character though, so it's a bit hard for me to say what she needs.