Yes, the first IXB was commissioned in december 1939. It should also be noted that several IXA boats which shared most features with IXB and are not modeled in SHIII were already in service by the start of the war.
Otherwise, I don't see it as a serious inaccuracy, even if U-64 technically didn't sail on combat patrol until March '39. Not a great discrepancy in the wider scope of things.
And oh, yes, I do believe this is more SH3 commander than NYGM
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There are only forty people in the world and five of them are hamburgers.
-Don Van Vliet (aka Captain Beefheart)
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