It looks to me as though you simply add the contents of COMMENT to GENRE
For that procedure, there is even a post in the FAQs:
In your case, I would create an action group with 3 actions:
- Format tag field for GENRE
Format string: %genre%\\%comment%
- Merge duplicat tag fields for GENRE
Separator: ;
- Replace for GENRE
Search: &
Replace with: ;
That should lead to the same result as your list. No ELSE required.