I don't mean to be argumentative but I also went through this entire process with a lawyer while drafting my lease and discussing security deposits. There is nothing on the page you referenced, nor in any of the legislature I've come across, nor anything that was mentioned by my attorney regarding a "security deposit account." The deposit only needs to be held in a separate, interest bearing account in a Massachusetts bank. There are then separate laws governing the lease and informing the tenant of said account. I have never heard of any state requiring a court order to withdraw funds from a security deposit, and it seems you're also finding it difficult to find this as well aside from what some judge explained to you at some point before.