In the 3 wire install, the requirement can be summarized as 'the combination EGC/neutral' must be suitable as a _neutral_ circuit conductor.
The bare wire in NM cable is _not_ considered suitable for this purpose.
The bare wire in SE cable _is_ considered suitable.
I don't know if this is a historical artifact, or if there is some requirements difference that makes the bare conductor in SE cable somehow better than the bare conductor in NM. I would note that the bare conductor in SE is regularly used as the neutral for a service.
(Or see the actual code posted at the same time I was writing this post....)
-Jon