I come across a number of pool wiring jobs, where the electricians cut as many corners as possible to keep costs down, and still remain legal. Unless I'm missing something, it seems that this may be legal.
The panel is an 8 circuit made for pool panel. It has a built in raintight outlet and two time clocks. This one has 2 double pole breakers for heater and pumps, 1 single pole breaker for under water lights, 1 single pole breaker for above ground landscape lights, and 2 single pole breakers for a small grill/ mini fridge setup. There are no GFCI breakers or devices in or at the panel. The panel is fed by a 50 amp GFCI breaker, which protects everything.