"DEALMAKER: At the beginning of the game, place a Loyalty token on another friendly character's card. The character with the Loyalty token modifies its attack and range values by +1. Any adjacent character can be given a free action to make a close attack targeting The Penguin. If hit, place the Loyalty token on the character card of the attacker's choice instead of dealing damage. When The Penguin is KO'd, remove the Loyalty token from the game."

From the 2015 Core Rulebook:

NO DAMAGE: An attack that deals no damage ignores modifiers to the damage value. Attacks that deal no damage deal neither critical hit damage to the target nor critical miss damage to the attacker (see Rolling 2 and 12: Critical Misses and Critical Hits, below). Attacks that deal no damage do not activate the Damage Depletion Modifier.

= = = = = = =

Assume the adjacent character in question rolls a Critical Miss against the Penguin while taking the free action to make the close attack to place the Loyalty token.

Does this attack count as a "No Damage" attack, per the rule book, or would the attacker take the damage for rolling a Critical Miss?

No, it's not a "no damage" attack. It has an effect that replaces damage on a hit, but if you roll a crit miss, your character is going to take the damage.

OK. That's what I figured when I rolled a Critical Miss with my Kingpin tonight, but I wanted to make sure.

Thanks, Lantern!