Workaround found:
i have to put a non-empty element before my first comment and the remaining content survives! - comments before the letter B in Bannerdummy of course are stripped :-)!!
the second div in
<div style="display:
none">Bannerdummy</div>
<div><!--banner starts--><em>Hello World</em><!--banner ends--></div>
is not touched, as long the first div is not empty :-)
please, fix this one, this workaround works for now (for today), but this is of course crap!