Hayes fired a 7-under 65 in the opening round to lead Cameron Beckman, Scott Verplank and Ryuji Imada by one shot. Woody Austin, coming off his recent success at the Presidents Cup, was among those tied at 67.
Hayes is currently 123rd on the tour's money list and only the top 125 earn a spot on next year's exempt list.
He birdied the first two holes at the Walt Disney World Resort's Magnolia Course and began the back nine with two straight birdies as well.
The opening round was played in windy conditions after rain had swept through the area.
"The conditions are just very sloppy," Verplank said. "It's fairly windy, so it is a little tougher than we're used to around here."