To be honest, I was thinking of something similar the other day, but far less likely to be effective.
A very radical shift in ship builds for such a vessel, and I have no clue whether this would be "meh" or considered OP. On the one hand, you could have a very tanky escort.
TT - APB - CRF - APO
EPtS - Aux2SIF - Aux2SIF - RSP
TSS - Hazards - TSS - PSW
Again, this came directly from stardestroyer's Random Thought Generator, and may be the stupidest or most OP idea on the planet. You've been advised.
I think it could be competitive - but in order to compensate for the lack of a Cmdr ability, I would say add an ensing and move one lT to ensign, or something else that increases the total number of boffs. That way, you have more boffs, and can take advantage of their traits in exchange for the missing commander ability.