I guess this leads me to the question of "Can we build a tier 3 Paladin?"
Now we mostly know that a paladin is a tier 5 class, but tiers have definitions.
And the definition for Tier 3 is
"Capable of doing one thing quite well, while still being useful when that one thing is inappropriate, or capable of doing all things, but not as well as classes that specialize in that area. Occasionally has a mechanical ability that can solve an encounter, but this is relatively rare and easy to deal with."
The Tier System has classes being able to shift up 2 tiers as part of it system.
So we only need to be able to do 1 thing well, and summon giant beat stick is pretty good. This isn't just any beat stick, this is a beat stick that has twice the HD of the other party members, which means it has options.
So lets work on what it can do well and try to get general use out of every other resource a paladin has that isn't his 5th level ability.
Lets give it VOP with its first two feats, so at 5th level it will start to get 4 bonus feats. Put the stat boost to Strength and Con, so its attack routine becomes 20/15/15 at d8+13/d6+7/d6+7, which is not too shabby. An AC of 23, 104hp, Saves of F13, R 7 W 5 and we still have 6 feats to play around with to help correct some of its issues, like its low Will save.
So is Wombat Beat Down good enough to qualify for "capable of doing one thing well" at this point?