Daly, who withdrew, missed the cut or was disqualified in his last seven PGA Tour events this season, had an eagle, five birdies and three bogeys in the round for a 7-under 137 total.
Daly, who entered the tournament late last week, is coming off a victory in the Korean Open in October. He finished 171st on the PGA Tour money list with $220,647 in 22 starts.
Scotland's Janice Moody, one 14 LPGA Tour players in the field, shot a 4-under 68 at Spyglass Hill to move into a second-place tie with Bo Van Pelt, Michael Muehr and Rob Oppenheim.
Van Pelt had a 64 at Pebble Beach, Muehr shot a 69 at Del Monte and Oppenheim had a 73 at Spyglass Hill.
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