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That's a good theory. I thought of a few side notes to it and a possible flaw with a portion of the theory.
Thought 1:The crew of the Lorelei seems to be murdering and poisoning some of the crew of the Graza; while the Graza crew that was dancing all got sliced. No distinction is made whether or not the Lorelei crew was real humans or ghosts at the time they murdered the Graza passengersexcept for one thing (see thought 2). However, when the Lorelei was sunk the Lorelei ghosts should have been free, so this makes us believe that the Lorelei crew were in fact alive when they murdered the Graza crew, however, see thought #2.
Thought 2:There is a scene about an hour into the movie where the Graza captain's ghost is drinking whiskey with the captain of the tugboat. The ghost shows him pictures that show the Lorelei sinking. The Graza came to the aid of the Lorelei. The dialog between the two is that there are no survivors of the Lorelei except for one (assumed to be the evil ferry man). The only part of this that I can't figure out is, the ghost says the Lorelei was "a drift". I always took this to mean the Lorelei sunk. But the tugboat captain says he heard of the story of the Lorelei and knew there were no survivorsso I wonder if the Lorelei didn't sink and was later found (after the Graza found it) otherwise how would the modern day tug boat captain no there were no survivorshowever, he could have meant there were no survivors because the boat sank. But if the Lorelei sank, then it's ghosts should have been freed like the Graza's ghosts. I suppose it makes no difference but it could go either way, either there's a hole in the plot, or it may make sense
Thought 3:Is the gold real or just an illusion? There's good points that it's an illusion. The ferry man seems to use desires as temptations, e.g., the food scene, tempting the last crew survivor (with blond hair) (Dodge was his name) to be a man and tell the woman how he feels, etc. Except for one thing, the end scene where people are loading the gold onto the modern day cruise ship. This could have been done though for drama.

I always thought Epps floated in the water for a couple of hours from when she blew up the ship during the night to which she got on the box chest and floated until the next morning when another ship rescued her.

As with others here, I think you described Ferriman's MO perfectly. My largest problem with the film is the ease with which people went swimming in the Bering sea. I'm an Alaskan, and have fished those waters; if you go overboard, especially without a survival suit, you are dead inside of 5 minutes. Hypothermia sets in within 3 minutes. They give the impression that she floated for hours, if not days. What a joke.

Not a dumb theory at all. I definitely agree. It's certainly plausible and makes perfect sense. That would indicate that that's how Jack Ferryman was able to lure a lot of people to the gold so well and "collect" their souls.

Makes sense to me as well.

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Makes sense to me.