The CIO of a financial services company is tasked with ensuring IT processes are in compliance with recently instituted regulatory changes. The FIRST course of action should be to:

Aligning the IT project portfolio is a subsequent step that relies on the findings of a current state assessment and gap analysis.

Creating an IT balanced scorecard is a performance measurement tool, not the initial action for addressing new regulatory compliance.

Identifying penalties for noncompliance is important for understanding risk, but it does not provide the actionable information needed to initiate compliance efforts; a current state assessment does.

Performing a current state assessment, or a gap analysis, is the foundational first step to understand where the existing IT processes stand in relation to the new regulatory requirements. This assessment identifies which processes are already compliant, which need modification, and what new controls or procedures must be implemented, providing a clear roadmap for achieving and demonstrating compliance.