Some states do not subject a towed vehicle to the same laws as trailers, but if it were a trailer, at 3300+ lbs it would definitely require brakes in nearly every state and Canadian province.
More important, though, are the laws of physics. Increasing the combined weight of your rig by 3300 or so lbs without increasing the braking capacity means the minimum stopping distance gets proportionally longer. A loaded 29R weighs in around 18,000 lbs, so adding another 3300 means about an 18% increase. Perhaps not important in routine driving, but when the times comes to slam on the brakes, you are gonna regret every foot of that extra distance.