IF they have a similar wipe potential, we don't need to talk about ppsh penals, or shocks inside the m3a1 but a single combat engineer with a roks-3 flamer is enough to wipe raks without the retreat ability in a matter of seconds, the 221 can come close but usually doesn't decrew at guns because allied players can have a ultra light vehicle of their own to hold it off, the armor upgrade comes rather late and is almost at the 222 timing.
If you would have tried playing the patch you would probably have noticed the weakness of the rak yourself.
M3 doesn't have much wipe potential on its own, its completely dependent on the package and regular blobbing if you expect that hardcounters it.