Richard H. Kirk Vice President, Corporate Counsel
	The Prudential Insurance Company of America 213 Washington Street, Newark, NJ 07102-2917 Tel 203-925-3707 richard.kirk@prudential.com

April 20, 2026

VIA EDGAR

Securities and Exchange Commission

100 F Street, N.E.

Washington, DC 20549

Members of the Commission:

I have acted as counsel to Pruco Life Insurance Company (the “Company”), in connection with the filing of the Post-Effective Amendment to the above-referenced Registration Statement on Form N-4 under the Securities Act of 1933. I have reviewed the establishment of the Pruco Life Modified Guaranteed Annuity Account (the “Guaranteed Account”) by the Board of Directors of the Company as a non-unitized separate account for assets applicable to certain market value adjustment annuity contracts.

I have examined or caused to be examined such documents and reviewed or caused to be reviewed such questions of law as I considered necessary and appropriate for the purpose of rendering this opinion. On the basis of such examination and review, it is my opinion that:

(1) the Company was duly organized under the laws of the State of Arizona and is a validly existing corporation;

(2) the Guaranteed Account has been duly created and is validly existing as a non-unitized separate account pursuant to the provisions of the State of Arizona law; and

(3) the market value adjustment annuity contracts are legal and binding obligations of the Company in accordance with their terms.

I hereby consent to the filing of this opinion as an exhibit to the Registration Statement.

Sincerely,