Comstock Metals Ltd. — Capital/Financing Update 2020

May 26, 2020

FORM 51-102F3 MATERIAL CHANGE REPORT

ITEM 1. Name and Address of Company

Comstock Metals Ltd. Suite 310 - 850 West Hastings Street Vancouver, British Columbia V6C 1E1

ITEM 2. Date of Material Change

May 26, 2020

• ITEM 3. News Releases

A press release in the form of Schedule A attached hereto was disseminated on May 26, 2020 via Newsfile, and subsequently filed on the System for Electronic Document Analysis and Retrieval (www.sedar.com).

ITEM 4. Summary of Material Change

Comstock Metals Ltd . (TSX-V:CSL) (“ Comstock ” or the “ Company ”) has announced that further to its press release on February 7, 2020, the consolidation of its common shares (" common shares ") on the basis of (1) post-consolidation share for every five (5) pre-consolidation shares (the " Consolidation ") will be effected at 12:01 a.m. on Tuesday, May 26, 2020. The Company's post-consolidation common shares are posted for trading on the TSX Venture Exchange as at the opening of trading on Tuesday, May 26, 2020, under the current symbol "CSL" and new CUSIP number 205719305.

ITEM 5. Full Description of Material Change

• 5.1 Full Description of Material Change

See Schedule A attached.

5.2 Disclosure for Restructuring Transactions

Not applicable.

• ITEM 6. Reliance on subsection 7.1(2) of National Instrument 51-102

Not applicable.

• ITEM 7. Omitted Information

Not applicable.

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• ITEM 8. Executive Officer

The following officer of the Company may be contacted for further information:

Steven H. Goldman President, CEO and Director Phone: (416) 867-9100 Email: s.goldman@goldmanhine.com ITEM 9. Date of Report

This report is dated this 26[th] day of May, 2020.

SCHEDULE A

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Correction of Source: Comstock Confirms Effective Date of Share Consolidation

Reference to the post-consolidation common share listing date is correctly stated as May 26, 2020.

Vancouver, BC – May 26, 2020 - Comstock Metals Ltd. (TSX-V: CSL) (“ CSL ” or the “ Company ”) announces further to its press release on February 7, 2020, the consolidation of its common shares ("common shares") on the basis of (1) post-consolidation share for every five (5) pre-consolidation shares (the "Consolidation") will be effected at 12:01 a.m. on Tuesday, May 26, 2020. The Company's post-consolidation common shares will be posted for trading on the TSX Venture Exchange at the opening of trading on Tuesday, May 26, 2020, under the current symbol "CSL" and new CUSIP number 205719305.

The Consolidation will result in the number of issued and outstanding common shares without par value of the Company being reduced from 92,747,530 common shares to approximately 18,549,506 common shares on a non-diluted basis, and each shareholder will hold the same percentage of common shares outstanding immediately after the Consolidation as such shareholder held immediately prior to the Consolidation. The exercise price and number of common shares of the Company issuable upon the exercise of outstanding stock options, warrants or other convertible securities will be proportionately adjusted to reflect the Consolidation in accordance with the terms of such securities.

Registered shareholders that hold physical share certificates will receive a letter of transmittal requesting that they forward pre-consolidation common share certificates to the Company's transfer agent, Computershare Trust Company of Canada, for exchange for new share certificates representing common shares on a post-consolidation basis.

About Comstock Metals Ltd.

Comstock Metals Ltd. is a diversified mineral exploration company advancing its wholly owned projects located in North America and holds several equity positions in companies with large mineral resources.

• 100% owned Preview SW Gold Project in Saskatchewan (43-101 Resource Stage)

• Joint Venture and equity investment with E3 Metals Corp. (TSX-V: ETMC), a petrolithium company developing lithium extraction technology in Alberta. (43-101 Resource Stage)

• Equity investment in White Gold Corp. (TSX-V: WGO) developing its portfolio of properties located in the White Gold District of the Yukon (43-101 Resource Stage)

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For more information about Comstock Metals Ltd., please visit www.comstock-metals.com or contact: Steven H. Goldman President, CEO and Director COMSTOCK METALS LTD. Phone: (416) 867-9100 Email: s.goldman@goldmanhine.com

Neither TSX Venture Exchange nor its Regulation Services Provider (as that term is defined in the policies of the TSX Venture Exchange) accepts responsibility for the adequacy or accuracy of this Release.

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