Highly possible my brain is not working this morning, but let's back up a bit and see if I am reading correctly.
Although the header is "sub panel" it sounds more like an added service panel.
OP says he has a 400 amp service feeding a 200 and 100 amp panel...not a 400 amp panel... goes on to say in post #4 that the 200 is MLO.
Depending on the number of breakers in the 200 (a) it may be a violation or (b) it may prevent adding the 3rd panel. I think we need more detail on the 200 amp panel.
Secondly, OP states (2) 60 amp heater circuits. If these are 9.6 kw heaters we seem to be fine, but if they are greater, the 100 amp would be inadequate.