Although compliant, a few other things to consider: I am not sure I would want to pull 12 conductors in a single pipe. Although the derating doesn't hurt you since you are presumably upsizing for VD, it just seems like a hassle all around. Also, you may want to look at your lug configurations. 400 amp equipment likely only has two hole lugs so you would have to transition from 3 down to 2 conductors which is added time and expense. If it's CT metered, then a 6067L mounting base has three holes (at least the brand I get) so you would be ok and could just go two sets from the CT to the Disco.