Once I asked my current T to say "I love you" to my child part. T had asked what that part needed. T said "I love HER", not "I love you". I asked her why she said it that way, at another session, and she said she reserves "I love you" for her family and close friends. I can understand that. However, she wrote "love and hugs" on the birthday card we made together the first year I was seeing her. I know writing "love" on a card is different. I sign emails and cards "love" to friends while I wouldn't say it to them in person.
I know that some Ts do say "I love you" to their clients, but I don't think it's appropriate except in rare circumstances. I think it would be confusing, but I suppose it depends on how and when it is said, and on the individual. If my T said it to me I'd definitely obsess forever about what she meant! I'm glad she made the distinction when she said "I love HER" that time. She never said that again, and I didn't ask her to.
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