Tom,
The difference between those two will probably not be noticed. The consensus seems to be that with the modern blends (particularly those with alcohol) it is better to be closer to TDC rather than further. I would think 36 would be fine as an example.
I have found that it is difficult to set the timing accurately using the static method. You can be a few degrees off. There is nothing wrong with that as long as the bike is happy. Most owners do not know what the timing is on their engine unless they strobe it, they can only tell you where they think they have set it. But that is good enough!
So, I would not worry too much. I would probably start at 38 and work from there.
David