Nah, just 9 I think... would have to look it up, though. If official stuff like this were always given also with a GMT/UTC time to avoid confusion this would be great.
I think it would probably be a better ability if it did just increase penetration (multiplication) or decreased the vehicle's armor (doesn't really matter which one for the calculation).
This would make it stronger (or keep it as strong) with units like the T-34s, Su-76, Guards' PTRS (they already have higher penetration than the T-34 O.o) and even increase the viability of other, sometimes overlooked soft counters like the T-70 (flank) that normally has a quite low chance to penetrate.
High penetration units like the Su-85 and AT guns wouldn't profit at all from it then, though.
Its current form can be perceived as problematic because it is a huge force multiplier for already strong units and does not do as much for low penetration units although its cost and commander placement (3 CP -> mid-game, commanders dedicated to counter vehicles) suggests that it should be used with early/mid-game units (NOT Su-85). Long range units (AT gun, Su-76) would still profit from the detection/tracking it grants).
Same for sandsack walls conscripts can build: They are unfinished so you can't even climb over them and they mess vehicles without medium crush up badly.