For that, yes - it was actual damage to the car, which is no different than a hail repair.Typically yes. And it's not necessarily a negative mark on the car - my '08 had a disclosed repair prior to my taking possession of it to the lower body panel under the front end bumper. They said it had been damaged when they unloaded it from the transporter, and they had replaced it with new Subaru-sourced sheet metal and had an outside body shop install it and match the paint.
It may sound like I'm nit-picking, but these are un-titled cars that are having a defective part replaced. There's no difference between us at the dealership level replacing them or if the folks at the plant go out into the yard, yank the column, and put in a new one.
So there's no disclosure necessary. Now, we may SAY something, depending upon the customer, but there's no requirement to do so, like there is with physical damage or hail repair, since the vehicle is completely covered by the manufacturer warranty.