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.
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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.
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