I'm working on this sentence: "The new rule should not affect section 2607 claims even if the claim does not allege a serious violation."
Do I need a comma before "even if"? I think "even if" is a subordinating conjunction here and starts an adverbial phrase. The phrase beginning with "even if" seems nonrestrictive to me so I'd say it needs a comma. Is that right?
EDIT: Slight change to phrase beginning with "even if" - the real thing is longer and more complex but I over-simplified it.