CSPA and my step-daughter

[andyrr 0]

Here is what I think are all the relevant dates:

1. Her Date of Birth: March 25, 1993.
   
2. Her mother (Legal Permanent Resident) applied for I-130 on January 13, 2014.
   
3. The I-130 was approved on February 27, 2014.
   
4. Her current Visa Bulletin Date is: January 1, 2013.
   

When I run these numbers through older CSPA calculators it says: Her current CSPA age is: 20 years, 9 months, and 18 days.

But, I understand that while the law hasn't changed, it's interpretation has.

Can someone tell me if she will be considered over or below 21 years?

I and her mother live in the US, she is hoping to come from Russia.