I'm going to say, No, it isn't missing the clad layer, at least from the looks on the photo you posted. It appears to be ED, environmental toning of some type. I may be wrong, but better photos, posted Full Image so they can easily be enlarged, might help.
i believe it is, was from a reputable error dealer..and coin is spotless except for the missing clad layer, let's see what the experts think?? anyways here are more pictures... @paddyman98 @Fred Weinberg