Shawn,
I believe you're right that there's no API that would insert a comment above a particular line. The only way I can imagine is to Open() it, Readline() each line, parse, and WriteLine() to a new file. One could create a comment= key with WriteProfileString() but its placement within the INI cannot be controlled.
_________________________
Give a man a fish and he will be back for more. Slap him with a fish and he will go away forever.