On systems from 10 years ago, it was common practice for an inverter to ground one of the polarities thru a GFCI fuse or breaker. That polarity would be the grounded conductor, and the standard required you to identify it as you'd identify any other grounded conductor, and label the inverter to inform the user of the possibility of an ungrounded white wire during a ground fault. The code didn't have the term "functionally grounded" at the time. In concept, a system like that could be built today, and the grounded polarity would be the "functionally grounded conductor". The current standard requires you to identify it, as if it were an ungrounded conductor, in contrast from the pre-2017 standards.