hello!
I had the same problem in the past when I found the for the fist time the Concept
FMEA in a Ford manual (FMEA version 31, section 3);it was decide to use:
-Concept FMEA: in the feasibility phase for the new or updated platforms; only potential customer are considered
-system FMEA: at the early phase of the development of a new system; the requirements have been fixed nd there is a nomination letter from the Customer
ciao