The first course of action for the CIO of a financial services company to ensure IT processes are in compliance with recently instituted regulatory changes should be to perform a current state assessment. This is because a current state assessment can help to evaluate the existing IT processes, policies, controls, and performance against the new regulatory requirements and identify any gaps, issues, or risks that need to be addressed. A current state assessment can also help to establish a baseline and a benchmark for measuring the progress and effectiveness of the compliance initiatives.

Aligning IT project portfolio with regulatory requirements is not the first course of action, as it is a subsequent step after performing a current state assessment. Aligning IT project portfolio with regulatory requirements can help to prioritize and allocate resources for the IT projects that support the compliance objectives and deliver value to the business. However, aligning IT project portfolio with regulatory requirements requires a clear understanding of the current state and the desired state of the IT processes and compliance.

Creating an IT balanced scorecard is not the first course of action, as it is a tool for monitoring and reporting the compliance outcomes and impacts. An IT balanced scorecard is a framework that measures and communicates the performance of the IT function in terms of financial, customer, internal process, and learning and growth perspectives. An IT balanced scorecard can help to align the IT strategy with the business strategy, track the progress and results of the IT initiatives, and demonstrate the value and contribution of IT to the business. However, creating an IT balanced scorecard does not provide a comprehensive analysis or improvement plan for the IT processes and compliance.

Identifying the penalties for noncompliance is not the first course of action, as it is only a motivation factor for compliance. Identifying the penalties for noncompliance can help to raise awareness and urgency of the compliance issues and risks, as well as deter or prevent violations or breaches. However, identifying the penalties for noncompliance does not provide a detailed assessment or guidance for achieving compliance.

References := IT Compliance: What You Need to Know | Smartsheet, How to Achieve Compliance section. IT Compliance Management Best Practices: 5 Tips from Experts - MetricStream, Tip 1: Assess your current state section. IT Compliance Checklist: How to Ensure Your Business Is Compliant - Blissfully, Step 1: Assess Your Current State section. IT Compliance Management - Definition & Overview | OpsCompass, How Do You Manage IT Compliance? section.