This is in a residence. The sub-panel is controlling HVAC equipment. At this point I really need to look into the application because the question asked of me is starting to get a little vague. Surely (hopefully) the equipment maintenance receptacle is installed. Where does it get its power I wonder?
In any case, the agreement seems to be in favor of a neutral only being required on SECs. I was lending to the grouping of multi-wire branch circuit conductors as the argument but they are not feeders. I personally would never allow such an application if I was the AHJ. The point being is this is a residence subject to who knows what kind of future work to be done.
Interesting discussion, thanks all.