TB, I disagree. Pentangeli tells Michael that he wants to run his family without Michael riding him about it. Michael confirms that Frankie is a Don by telling him that he is to run his family like a Corleone. There is nothing to indicate otherwise, offically or not.
The FBI chart shown at the Senate hearing lists Pentangeli as a caporegime. That Frankie tells Michael that "I wanna run
my family without you on my back..." [emphasis added] tells me Frankie saw the men under him as his family unit and he resented Michael telling him what to do vis a vis the Rosatos. But it doesn't necessarily connote Frankie as an independent Don--if he were, he wouldn't be in Tahoe pleading with Michael.