Answer:
Not to put too fine a point on your question, but the distinction in Regulation E is between oral stop orders and those that are not orally delivered. NACHA uses the word "verbal," but is referring to oral stop orders. The distinction is whether the order is spoken or not.
I would definitely not characterize a stop payment made via internet banking as "oral." Although it's electronically delivered, it's still a written order (just to anticipate a question, it's not subject to E-Sign requirements). As for a stop made via telephone banking, it might be oral, depending on how the information is recorded (voice versus touch-tone input), and even a voice recording could be considered a written record in some jurisdictions.
All of that doesn't really get to the core of the question, which is undoubtedly whether such a stop payment has to be confirmed in writing. The answer to that is going to sound a bit evasive -- you don't have to require that a customer confirm a stop payment order in writing; the rules simply say that you may impose that requirement on an oral stop payment order.
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