It is kinda UP because it cost you a card to draw 2 (3) cards, opponent draws the same. Which gives you -1 card advantage. But it trades speed for card disadvantage.
Drawing independently from opponent has been proven OP, as it is the SoB in Trainer used to do. It gives a... what? 3 ttw? 2?
Also, this card is buggy. Hope Zanz fixed it, but this is not the place to talk about SoB bugs.