Former Rams safety Oshiomogho Atogwe became a free agent after midnight Tuesday. He did not become an unrestricted free agent as defined by the collective bargaining agreement.
The distinction is important for the Rams because it means Atogwe would not count in the formula used to award compensatory draft choices if he signed with another team. That formula takes into account net losses in unrestricted free agency when determining which teams should receive 32 additional picks each year.
Atogwe is unrestricted only in the sense that he is free to sign with any team. That does not make him an unrestricted free agent by the NFL's definition and it's therefore incorrect to refer to him as a UFA. The NFL has confirmed the distinction.