i dont know about 230.32, but 250.32(b(2) says:
Grounded Conductor Where (1) an equipment grounding conductor is not run with the supply to the building or structure, (2) there are no continuous metallic paths bonded to the grounding system in each building or structure involved, and (3) ground-fault protection of equipment has not been installed on the supply side of the feeder(s), the grounded conductor run with the supply to the building or structure shall be connected to the building or structure disconnecting means and to the grounding electrode(s) and shall be used for grounding or bonding of equipment, structures, or frames required to be grounded or bonded.
So, i figured that #3 of this paragraph meant that if the feeders have OCP that you need you cannot use this rule, but by your post im guessing that the code is refering to any GFI breakers that are in the panel, right. sorry, sometimes it seems like the NEC is written Japanese.