Given the amount of the prepayment penalty you almost certainly with have a section 32/HOEPA loan. You can eliminate the concern by converting your $250 fee to a 2% of the amount prepaid fee.
The regulations do not mention using the amount of fees paid on the consumer’s behalf as an offset against the prepayment penalty. The regulations do mention that fees paid by the creditor on behalf of the consumer are prepayment penalties if reinstated in the event of prepayment.