OK, slight correction. By "controllers" I guess I meant "parameters". I have three "controllers" totaling 40 knobs/sliders. I have mapped them in MIDI-OX to one MIDI loopback device which Sonar sees. This all works fine.
But anyway, only 16 parameters can be assigned to plugins at a time. There are another 16 that are reserved for controlling host parameters. The VST I'm using is an FM synth that has at least 100 parameters.
One solution I tried was to create 2 ACT controller instances, but then it turns out that only one of them can control a given VST at a time so that's no help.
This is the ACT UI I'm talking about: