Joe,
In your last picture, there are code violations in the use of the split bolts. They are not listed for use with that many conductors and you could cite that violation. The panel also does not have an equipment grounding terminal bar which has been required for many years by 384.27 and later by 384.20 or 408.20.
The rule in 384-20 or now 408.20 was added to the code a long time ago to put a stop to this method.
The rule was placed into the code to prevent the direct connection of EGC to the panel enclosure. Nothing in the current code section says that every EGC must be directly landed to the equipment grounding bar. In the '87 code section 384.27 required that "all" of the feeder or branch circuit EGCs to be connected to the equipment grounding bar. When the section was rewritten and relocated to 384.20 in the '90 code the word "all" was deleted from the section. The code no longer clearly requires that all of the EGCs be directly connected to the equipment grounding terminal bar. There was no reason given in the TCR for the deletion of this word. It may have been unintentional. The word "all" should be put back into the section, but as the code stands now, it does not support the opinion that all of the EGCs must be directly landed to the terminal bar.
What's so hard about installing a simple terminal bar in an existing panel?
Nothing is hard about this and this is the way that the installation should be done, but this thread is not about how things should be done. It is about the absolute minimum requirements that can be supported by the current code language.
Don