IMO, you're not too far from MBL.
This is just my opinion but everyone has different heights, wears different bras etc. Not everyone's MBL will be the same. I've seen some member here, and their hair will be touching their APL, but I'll see another member who's hair looks the same length but it's touching her BSL, because of the differences in height, I'm hoping I'm making sense.
Also some people wear their bra really low and are dissapointed that they arent BSL but if they wore their bra 2 inches higher like member XYZ does then they would be BSL already. For this reason I will not even count BSL for me. It's the only length than is not measure by a part of the body. I'll be going from APL then MBL. I dont really want MBL but i'm just saying.
What i mean is that I think your bra is lower than most, and I think you're close to MBL.
Anyway, your hair is beautiful. And I'm not just saying that, I noticed it in the OT forum. So don't be discouraged. I'd be happy to have just half of that right now.