Not my understanding at all. They are confidential. You don't need to tell anyone, period, and they are not disclosed in a PRIA search which is intentional by the FAA. It's not a matter of honesty- be honest with your conscience and do straightforward business with your employer. Hopefully there's no conflict, but in this case there is one. If you cannot distinguish between conscience and employer then fine, give them whatever they ask for but you are undermining the FAA warning letter system in so doing and making the personal rights of other pilots less practical as well.

You really don't trust the FAA, do you? Is that the real issue here?