Whether or not the state law will apply to a national bank or federal savings association is a matter that will keep the attorneys busy (and billing) for a long time, I think. I'll stay out of that controversy.
As for Pam's initial question, I think the 11/5 "Industry Advisory Letter" at http://mass.gov/dob/mlprepay.htm
provides an answer. It's buried in the last two paragraphs, and I read it to say "No worries." It appears that early closing fees are not considered prepayment penalties by the Commissioner.