Oh aye, it's a tricky one and I'm just "talking it out" and very interested in your and others thoughts on it

. It gets more complicated because some of the problems both the Germans and Americans had was because of fairly advanced magnetic detonators - so, in theory, if they don't research these by the time the war breaks out, then they shouldn't have as many problems with their torpedoes (they'd still have issues with impact detonators, but so did most of the world's navies except the Japanese, so this is probably better handled by a Japanese buff than an everyone-else nerf, and then another tech step or similar to get beyond the issue) - so, ironically, a 'torpedo research' NF before the war could plausibly result in less reliable torpedoes when hostilities break out (which, or course, no sane player would choose).
Given that, I'm leaning towards (for the naval mod I'm putting together, the base game will have what it already has in there at the moment I'd say, beta and all) the US and Germans having researched whatever torpedo tech gives them magnetic detonators at game start, along with some kind of 'new tech doesn't work like we'd hoped' malus, and then an NF to sort things out that can't be triggered until war breaks out - so at the start of the war their torpedoes will still sink a lot of ships (I'm currently going through the RN starting line-up ship-by-ship, and the KM sunk plenty of RN ships with their dodgy torpedoes) and then once they've sorted out the issues (if they choose to), they'll become even more deadly, with the same thing happening for the US. It is a bit 'railroaded', in that it assumes the US and Germany go for the advanced torpedoes before the game starts, but they were taking this approach pre-1936, so it's not crazy for them to do so. It may well work out that they could potentially rush the next tech to help limit whatever malus was in place.
Thinking it through - it'd probably be necessary to give the same malus to other nations of they decided to research those techs before war broke out - so if a UK or Italian player decides to go for advanced detonators as well, they have the malus added - otherwise they could start the war with even better torpedoes, which wouldn't make a lot of sense. Argh, complicated

.