Yes that is what he is asking and I do not think it can be answered here with the info given.
We have no idea what the connected load of the 100 amp sub feed is, an AC unit with a 40 amp breaker does not draw 40 amps and 10 20 amp SP breakers do not draw 200 amps.
There are only two ways to answer this.
1)Take real load measurements with an amp clamp. On a large job we would put in a data logger for a few days to a week.
2)Do the load calculations from the NEC.
I was just at a commercial job looking at a 400 amp panel with six 200 and two 100 amp 3 phase breakers in it (1400 amps total).
Was this panel maxed out?
I would have to say no as it has been that way for many years.