Mark Hensby, Kyle Stanley and Andres Gonzales were tied at the top with Toms, who is no longer ranked among the top 64 players in the world and thus was ineligible for this week's WGC Match Play Championship.
Toms won the match play event six years ago.
Jhonattan Vegas, who won earlier this year at the Bob Hope Classic, shot a 75 and was in a tie for 97th place.
John Daly had a 74 at the El Camaleon Golf Club.
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