I've read the entire small entity guide and commentary and don't see any mention of rescission. Since HELOCs will soon be reportable, do we still report a HELOC loan that was subsequently rescinded as approved not accepted?

Yes you do.

From the analysis and the referenced comment:

Few commenters addressed the proposal regarding rescinded loans. One commenter supported the proposal because it provided a consistent reporting rule. Another commenter stated that the proposal would provide consistency, but argued that the number of rescinded loans is so small that the change would not be worth the regulatory compliance cost. The Bureau believes that approved but not accepted most accurately reflects the outcome of a rescinded transaction, and that a consistent reporting rule for rescinded loans is appropriate and justifies any compliance burden. Therefore, it is finalizing comment 4(a)(8)-2 generally as proposed, but with minor technical revisions, renumbered as comment 4(a)(8)(i)-10.

Comment 4(a)(8)(10)

ACTION TAKEN—RESCINDED TRANSACTIONS.
If a borrower rescinds a transaction after closing and before a financial institution is required to submit its loan/application register containing the information for the transaction under § 1003.5(a), the institution reports the transaction as an application that was approved but not accepted.

Thanks, Kathleen. I completely missed that in the commentary.

Has anyone found anything with regards to rescinded loans that closed as a result of an accepted counter offer? I'm wondering what amount should be reported and what action taken should be used. Would this be one of those pick a way and stick to it situations?