very confusing... so my trailer having a gross weight of 2990 does not legally have to have brakes according to your findings.
That's exactly why your trailer has a GVWR of 2990. It likely has all 3500 lb. components but since it has no brakes the GVWR is 2990. My 6x12 enclosed is the same way with no brakes. My dad has the same exact trailer with brakes, GVWR is 3500.
1998 Gulfstream Ultra B/H Ford E450 V10
2005 Chevy 2500HD 6.0 w/ Maxidump insert
2006 Ford Escape Hybrid
1998 Saturn SL2 toad
2012 VW Jetta S