HT-el services that meet the principles of openness, timeliness, speed, convenience and affordability that are the ideals of PermenATR / KBPN 9/2019 are a little "tarnished" by the existence of an article that does not accommodate these conveniences, namely in Article 9 paragraph 5 Permen ATR / KBPN 9/2019 which states that "Requirements in the form of a Certificate of Land Rights or Ownership Rights in a Flats Unit must be in the name of the debtor." What if the certificate is in the name of the guarantor or another party, whose name is not the debtor. Is the certificate of land rights then can not be encumbered with mortgage rights?. The purpose of this research article is to provide understanding for the people who are of course the target for the use or implementation of this HT-el. The research method in writing this article is a normative juridical approach where legal research is carried out by examining library materials or secondary data as a basis for research by searching for the regulations and literature relating to the problem under study. The results of this study are that changes must be made to PermenAg No. 9/2019 especially in Article 9 paragraph 5 which states that "Requirements in the form of a Certificate of Land Rights or Ownership Rights in a Flats Unit must be in the name of the debtor" to "Requirements in the form of Certificates of Land Rights or Ownership Rights in the Flats must be in the name of the giver mortgage right".