Is a report required to be kept under the SPA?

34. It is somewhat difficult to resolve this part of the dispute because there are no documents before me to consider. In general, I find that a report is a document that includes a description of repair and maintenance work that was either performed, anticipated, or recommended. As for invoices and receipts, they are not included in the list of records the strata must keep under section 35 of the SPA, so they are not producible under section 36. See The Owners, Strata Plan NWS 1018 v. Hamilton, 2019 BCSC 863. That said, some contractors provide descriptions of work done and other information in their invoices, which may make the invoice a “report” that the strata must keep. With that general description, the strata must use its judgment determine whether it has any reports in its possession about its plumbing system.